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COUNTER-CLAIM
and through Undersigned Counsel, and Hereby Respectfully pleads the following
1. By Warranty Deed dated August 20, 2010 and recorded on August 23, 2010 at
Volume 988, Pages 532–533 of the Land Records of the Town of Farmington,
Counterclaim Plaintiff Fotis Dulos and his wife, Jennifer Dulos, took title to the subject-
11, 2017 to the Connecticut Superior Court of and for the Judicial District of Stamford-
Norwalk at Stamford, entitled Jennifer R Dulos v. Fotis Dulos, and bearing docket
4. By Quit Claim Deed dated August 16, 2019 and recorded at Volume 1181,
Pages 1090–1091 of the Land Records of the Town of Farmington, Gloria Farber
(“Ms. Farber”), utilizing a Power of Attorney dated April 26, 2017, which Power of
Attorney along with the accompanying Affidavit of Ms. Farber is recorded at Volume
1182, Pages 688–672 of the Land Records of the Town of Farmington, transferred the
organized and existing under the laws of the State of Connecticut, the assets of which
6. Such interest, at the time of transfer, was worth a considerable sum of money
and is a marital asset subject to distribution and allocation in the dissolution action
referenced above;
1. Counterclaim Plaintiff Fotis Dulos and his wife, Jennifer Dulos, by virtue of a
Warranty Deed dated August 20, 2010 and recorded on August 23, 2010 at Volume
988, Pages 532–533 of the Land Records of the Town of Farmington, are the owners,
as joint tenants with right of survivorship, of a certain piece and parcel of land situated
Jefferson Crossing;
2. Counterclaim Plaintiff Fotis Dulos and his wife, Jennifer Dulos, are lawfully
FIRST PIECE:
SECOND PIECE:
organized and existing under the laws of the State of Connecticut, the assets of which
4. By Quit Claim Deed dated August 16, 2019 and recorded at Volume 1181,
Pages 1090–1091 of the Land Records of the Town of Farmington, Gloria Farber
(“Ms. Farber”), utilizing a Power of Attorney dated April 26, 2017, which Power of
Attorney along with the accompanying Affidavit of Ms. Farber is recorded at Volume
1182, Pages 688–672 of the Land Records of the Town of Farmington, transferred the
5. By virtue of the Quit Claim Deed dated August 16, 2019 and referenced above,
thereof;
action commenced on or about June 20, 2017 by Jennifer Dulos against Counterclaim
Plaintiff Fotis Dulos, returnable on July 11, 2017 to the Connecticut Superior Court of
and for the Judicial District of Stamford-Norwalk at Stamford, entitled Jennifer R Dulos
parts thereof is adverse to the title and interest of Counterclaim Plaintiff thereto and
therein;
rights and interests of the parties in or to the property and settling the title thereto.
and Claims:
as to Count One:
1. Money damages;
as to Count Two:
RESPECTFULLY SUBMITTED,
THE DEFENDANTS, FOTIS DULOS
AND FORE GROUP, LLC, AND
COUNTERCLAIM PLAINTIFF,
FOTIS DULOS, BY THEIR ATTORNEY,
______________________________
MICHAEL J. HABIB, ESQ.
WILLCUTTS & HABIB LLC
100 PEARL ST, 14TH FLR
HARTFORD, CT 06103
TEL: (860) 863-4574
FAX: (860) 863-4625
E-Mail: Mike@InzitariLawOffice.com
Juris No.: 434008
AD DAMNUM
costs.
RESPECTFULLY SUBMITTED,
THE DEFENDANTS, FOTIS DULOS
AND FORE GROUP, LLC, AND
COUNTERCLAIM PLAINTIFF,
FOTIS DULOS,
BY THEIR ATTORNEY,
______________________________
MICHAEL J. HABIB, ESQ.
WILLCUTTS & HABIB LLC
100 PEARL ST, 14TH FLR
HARTFORD, CT 06103
TEL: (860) 863-4574
FAX: (860) 863-4625
E-Mail: Mike@InzitariLawOffice.com
Juris No.: 434008
JANUARY 10, 2020, to all counsel and pro se parties of record, as more specifically
follows:
_______________________________
MICHAEL J. HABIB, ESQ.
Commissioner of the Superior Court