Free Affidavit - District Court of Connecticut - Connecticut

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unirsc states DISTRICT I
oisfnicf or connecticut *·" M III I I
K.L.C.. INC., KEYSTONE LEASING
Plaintiff :
: CIVIL NO. 303CV1043# SRU
VS. : I
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CYNTHIA TRAYNEFI : I
Defendant : I
: OCTOBER 27. 2003
AFFIDAVII IN SUPPORT OF MOTION TO FIEOPEN DEFAULT
I, Cynthia Trayner, being duly sworn, depose and say:
1. I am over the age of eighteen (18) and believe in the obligations of an
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oath.
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2. I am the named Defendant in the above entitled action, and am the
owner of the premises sought to be foreclosed.
3. Prior to commencing this foreclosure action, I was a named defendant
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in an action entitled l<.L.C., Inc., Keystone Leasing vs. Trayner Transgort, et.aIs., I
which case was commenced by this same plaintiff in the Superior Court for the
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State of Connecticut, Judicial District of Hartford. Case No. CV O2 08201755 I
I“State Case")
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LAW oevices · 0* mEN. SHAPNER. STUART, KELLY & MORRIS. F.C- i
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Q __ _ OCT. 27.2003 2:53PM O'BRlEN SHAFNER _ 0092 P 3 I
C se 3:03-cv-O104ۤRU Document 15 Filed 10/3QN/@03 age of 3 I
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4. Judgment was entered in the State Case in the amount of
$101,628.45 and on or about June 27, 2003, I received a notice tram Keystone's
counsel that I was ordered to make weekly payments of $35.00 on said judgment
beginning June T7, 2003. A copy of said notice is attached as Exhibit A.
5. I commenced making weekly payments pursuant to the court order
and have continued to make weekly payments.
6. On June 13, 2003, roughly coincident with receipt of the notice to
commence weekly payments on the State Case, Keystone started this foreclosure
action and I received notice of the commencement of this case.
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7. Although 1 did speak to a lawyer after I received notice of this case, 0
and did file an appearance, I did not fully understand that Keystone could foreclose I
on my home while I was making weekly payments on the judgment. l also did not I
understand that I had to file an answer to the complaint or risk having a default
judgment enter against me. Had I understood that, I would have retained a lawyer
and filed answer to the complaint.
8. I believe that there is no equity in my home and that it is inequitable {
for the court to enter a foreclosure of the l I
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LAW crrlclts · OIBRIEN, SHAFNER, STUART, KELLY Be MORRIS, P.C. I
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IS l‘l0'IZ 3 COl'\SUlTl6l' debt, since my debt to KEYSIZOFIB is BS 3 gL.l&l‘&fT[Ol’ of 3 I
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commercial transaction, I would like an opportunity to request a stay of the
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foreclosure of my home as long as I continue to make weekly payments as ordered
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by the Superior Court. I
9. For the above reasons, I am requesting that the default be reopened in
order that my counsel be permitted to file a responsive pleading to the complaint
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and pursue a stay of this matter. I
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‘ n ia Trayn
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Subscribed and sworn to before me on this QB day of October I
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Notary Public-
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