Free Answer to Complaint - District Court of Connecticut - Connecticut

Case 3:03-cv-00933-WIG

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Filed 05/19/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Sammie Goss Shadow Maynard Plaintiffs vs.

Stratford Housing Authority Steven Nacano Defendants

: : : : : : : : : :

Civil Action No. 3:03 cv 933 (WIG)

May 17, 2005

ANSWER

The Defendants respond to the Plaintiffs' complaint under Section C. NATURE OF THE CASE as follows:

1.

As to the allegation(s) beginning with "Being 56, widowed..." through and

including the phrase "I was not in an assessable apt.", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof. 2. As to the allegation "November 20, 2001 I applied for elder/disabled housing

in Stratford HA", the Defendants admit that Plaintiff Sammie Goss applied for public housing assistance. As to the date of such application as alleged, the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof.

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3.

As to the allegation(s) beginning with "March 2002 I sent a copy of

Medicaid denial..." through and including the phrase "I need wheelchair and assessable apartment `ASAP'. Her note-ignored.", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof. 4. As to the allegation(s) beginning with "May 2002 I received a Section 8

voucher..." through and including the phrase "the voucher port there also", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof. 5. As to the allegation(s) beginning with "When it came time to renew or extend my voucher..." through and including the phrase "one of my disabilities is partial deafness.", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof. 6. As to the allegation(s) stating "He told me by phone September 2002 `we do

not extend our vouchers' he ignored my request for my number on disabled/housing list", the Defendants deny the allegations in their entirety. 7. As to the allegation(s) "Also, future disabled 18-61 should never go through

what I have, to present.", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof. The Defendants respond to the Plaintiffs' complaint under Section D. CAUSE OF ACTION as follows:

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8.

As to the allegation(s) beginning with the phrase "Violation of HUD..."

through and including the phrase "service dog also" the Defendants deny the allegations in their entirety. 9. As to the allegation(s) beginning with the phrase "I am a brain and spinal

injury survivor..." through and including the phrase "I do not understand this section", the Defendants are without knowledge or information sufficient to form a belief as to the truth of the averment, and therefore leave the Plaintiffs to their proof.

AFFIRMATIVE DEFENSE As to the Plaintiffs' implied allegation that the Stratford Housing Authority wrongfully refused to extend the housing voucher, the Defendants' proffer the following affirmative defense: 1. The Stratford Housing Authority's jurisdiction to extend the time of housing

vouchers was and is limited by the applicable annual agency plan. Under the applicable plan, the term of a housing voucher could not exceed one hundred twenty (120) days including any and all extensions. Sammie Goss was given a housing voucher that, with extensions, remained in effect for one hundred twenty (120) days. As such, the Stratford Housing Authority was legally barred from making any further extension.

_______________________ Charles T. Forman Federal Bar # CT 17039 Thornberry & Forman, LLC 3333 Main Street Stratford, CT 06614 Tel. (203) 380-8189 Fax (203) 380-8191

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CERTIFICATE OF SERVICE This is to certify that on May 17, 2005 a true copy of the foregoing was sent via first class postage pre-paid U.S. Mail to the following: Sammie Goss P.O. Box 320834 Fairfield, CT 06825

_______________________ Charles T. Forman

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