2026-10-06 - Fair Rent Commission

00:00the meeting of the Fair Rent Commission

00:02on Monday, October 5th. The time is 7

00:04o'clock and we're going to stand for the

00:08flag salute.

00:14I

00:14>> aliance to the flag of the United States

00:17of America and to the republic for which

00:20it stands, one nation under God,

00:23indivisible, with liberty and justice

00:26for all.

00:28Alrighty.

00:31And if I can have attorney Martacio um

00:34do a roll call vote. A roll call,

00:36please.

00:37>> Yes. M Subhansky

00:39>> here.

00:40>> Mr. Tundan

00:41>> here.

00:42>> Mr. Coella

00:43>> here.

00:43>> Mr. Got

00:44>> here. Miss Dolan

00:47absent.

00:48>> Mr. Bunko

00:50absent.

00:53Miss O'Banski

00:56>> here.

00:58Okay, before we start, I just want to

01:00introduce myself. I'm Susan Zabahansky.

01:02I'm the chairwoman of the Southernington

01:03Fair Rent Commission and um Gotautle is

01:07our vice chair and serving today. Um and

01:12we have to take I guess we'll have to

01:13take a vote to um vote in our alternate

01:16because Mr. Bunko is not here. I'm I am

01:19the um tenant um portion. So, we have to

01:22have an equal number of landlords and

01:24tenants serving on the board and we have

01:26to need we need five for quorum. So,

01:28we're going to take them. Uh

01:29>> I do have a question though. Actually,

01:31it's it's it's for you. Um when I w I

01:35wasn't at the first meeting and

01:37technically it would only take us five

01:39minutes and I know it's going to be the

01:41same, but procedurally there was not a

01:45correct quorum on that meeting for

01:48voting people in.

01:50>> Which which meeting? very first meeting

01:53there was not a quorum because they put

01:56Stacy instead of me. Stacy is a renter.

01:59She cannot take the place of a general

02:02member. And it's going to stay the same,

02:04but I still feel better.

02:05>> Attorney procedural.

02:07>> This is out of order.

02:08>> No, it is not. Robert's world says I can

02:11do this. If there is a procedural

02:14concern,

02:15>> but

02:16>> if this isn't done, then I will get up

02:19and leave because I am not going to not

02:21follow procedure.

02:23>> You're going to exit the meeting?

02:25>> Yes, I will.

02:26>> Can we move this to unfinished business

02:28at the end?

02:29>> No, we

02:30>> even though it's not going to change

02:31anything procedurally for tonight's

02:32meeting.

02:34>> So,

02:35this is not on the agenda and we have to

02:37it's a special meeting. So, we have to

02:38follow the agenda the way it's written

02:40today. Not if there is a procedural

02:42issue and there is

02:45>> and your procedural issue

02:47>> by the time you're talking all this we

02:48could have had the vote done by now

02:50>> but you believe the procedural issues

02:52>> it was it's wrong

02:54>> I'm asking you what the procedural issue

02:56you believe is

02:56>> the procedural issue is there was not a

02:58quorum for that vote you cannot have a

03:03you can you have to stay the same so

03:05only a general member can take over my

03:08vote okay

03:09>> attorney Marti

03:11I'll let her finish.

03:12>> Y I didn't give her the floor.

03:15>> And and so Stacy took her own vote. She

03:18is a renter. But not only that, if you

03:20look at the step and the procedures,

03:23there has to be even numbers of renters

03:26and landlords for it to be fair. So

03:29there was two renters voting and only

03:32one landlord.

03:33>> That's for for hearings. We need to have

03:37>> an equal number.

03:37>> That's for all proceedings. We're going

03:39to let each other speak, but the only

03:41thing I'll note is I'm more than happy

03:43to look into this and research it. I

03:45mean, obviously this is the first I'm

03:46hearing of it. Now, I certainly would

03:48have appreciated hearing it a little

03:50beforehand, but in any event, if you

03:52choose to walk out of this meeting,

03:55that's your prerogative.

03:56>> Well, then you can't have the meeting

03:57because there has to be one Dem here.

04:00No, it is not. You must have one

04:03minority representation.

04:05>> We We don't have to have that to have a

04:07hearing. attorney. Can you pull up the

04:09Can you pull up the ordinance?

04:10>> Go right up.

04:10>> This is This is not in order and it's

04:12not on the agenda. So, we can't we

04:13shouldn't even be discussing it.

04:15>> Yeah. I'm going to recommend that we

04:16stick to the

04:16>> You are technically um if this isn't

04:19discussed, you are technically not the

04:20chair right now. So, if you don't want

04:23to do a vote where you become the chair,

04:25you're making a big deal out of nothing.

04:28>> This is all out of order.

04:30>> Yeah. I would

04:31>> You're out of order.

04:32>> No, you're out of order. You're

04:34technically not the chair.

04:37Look at you want me to go and read

04:39everything for the this that says for

04:41elections and votes. I have it all

04:44highlighted

04:45>> through the whole fair rent thing. And

04:47the reason I did not reach out every

04:49time I have reached out in the last two

04:51weeks I have with every one of you.

04:57>> I this is all news to me and like I said

04:58I'm more than happy to do some research

05:00and issue legal opinion. I'd certainly

05:02feel bad for all of the people that have

05:04attended today. But if you're insisting

05:06that we cannot go forward with tonight's

05:08meeting,

05:08>> that is not what I'm assisting

05:10assistsing. I said make a you we could

05:13have voted already.

05:15>> Okay.

05:16>> We don't know what we're voting on and

05:18we can't we can't have a vote because

05:19there's not this is a special meeting.

05:22In a special meeting, there is an

05:24agenda. We must follow the agenda.

05:26That's Robert's rules of order.

05:28>> Yes. in add

05:30or subtract anything to the agenda. This

05:32is a special meeting. It's not our it's

05:35not our procedural meeting.

05:37>> We technically don't have a fair rank

05:40commission. We have members. We do not

05:42have a chair or a vice chair without a

05:46proper uh quorum and a vote.

05:49>> Okay. And I I will note I wasn't at that

05:51initial meeting.

05:52>> Uh exactly. You weren't there either. So

05:53a lawyer wasn't there and other people

05:56were not there. Well, the the meeting

05:58can happen without a lawyer. That's not

05:59>> But a quorum for a quorum for a meeting,

06:03a regular meeting does not have to have

06:05you can look it up in the town statutes

06:07right now if you'd like.

06:08>> I'm more than happy to take the

06:10necessary time,

06:11>> but we can't even discuss

06:12>> if you would if you wouldn't mind. I'd

06:14rather not have to kill a part of a day

06:17having to come back here and give up my

06:20part of my day job.

06:21>> Yeah.

06:22>> So, you wouldn't mind taking a quick

06:23look at that.

06:24>> Briefly adjourn. Yeah,

06:26>> we can briefly adjourn.

06:27>> I mean,

06:28>> um, except we shouldn't even be

06:30discussing this because it's not on the

06:32agenda. This is special.

06:32>> Well, I I certainly defer to you as the

06:34chair. I mean, if if there is a legal

06:37question as to whether or not the fair

06:39rent commission has a chair. I'd

06:41certainly recommend we exercise some

06:43caution to make sure that we have the

06:45legal authority to move forward.

06:46>> I have our fair things right here. if

06:49you'd like to come over and look at it.

06:52>> We're going to We can

06:55>> a recess.

06:56>> Yeah.

06:57>> Okay. So, we need to take a motion to

06:58recess.

07:00>> All right. I'll have a motion to recess.

07:02>> Favor.

07:03>> Motion to recess.

07:04>> All in favor signify by saying I.

07:06>> I.

07:07>> Any opposed?

07:23We're going to call the meeting of the

07:25Fair Rent Commission back to order at

07:297:23

07:32and we're going to continue on. Um, so

07:35we were in the process of is Miss

07:37Kiello, Commissioner Kiello, are you

07:39going to be staying?

07:40>> No. And I am getting a paper that says

07:42there must be one minority on all boards

07:46and commissions everywhere.

07:49>> Backing up a little bit to make it

07:51clear. Uh I heard Miss Kovella's

07:55concerns and spoke with her. Uh I

07:57disagree with her assertion that Miss

08:01Abahansky is not the chair. Uh she was

08:05voted at the June 9th meeting. Those

08:07meeting minutes were approved at the

08:09July 22nd meeting. Uh, I believe that

08:12section 33b of the charter was followed.

08:15Uh, so I respectfully disagree with Miss

08:17Koviello's assertions.

08:19>> Okay. So, we'll go with that. But bottom

08:21line, if I leave today, if I leave

08:25today, right here in the in the

08:27paperwork, these are laws. It says,

08:30"Yes, fair ride commissions are

08:32government agencies subject to the

08:34minority party representation. statute

08:386GS

08:3991678

08:42which limits the maximum number of

08:44members of a board who can be registered

08:46in the same political party. So this

08:50room will be left with all Republicans.

08:53>> And I'll note for the record, I don't

08:55know what law you were citing, but 33B

08:58of the charter does say membership quote

09:01membership shall follow minority

09:02representation guidelines as s forth in

09:05the Southernington Town Charter. Uh and

09:08as comprised I believe the board does

09:10satisfy that requirement. Uh

09:13>> how would it

09:15>> I'm not going to engage in unnecessary

09:18engagement back and forth. We we have to

09:19continue the meeting.

09:20>> You guys don't want to do things fair.

09:21This is supposed to be a fair rent

09:22commission.

09:23>> Miss K, you're out of order.

09:26>> We're not in order, lady. I really don't

09:29care.

09:30>> She has to

09:30>> There will not be a Democratic person in

09:33this room. She has to be removed if

09:35she's continues to be at order.

09:37>> It's not going to be a democratic

09:39assert. We're going to

09:41>> Well, then I will put any formal

09:43complaint.

09:44>> And anything that's done here

09:47>> can not work, just so you know. Okay.

09:50We're going to have some control.

09:51>> She's out of order. She's out of order.

09:53She needs to be removed. You and your

09:55out of order. You're looking for

09:56Robert's rules of order. And it says

09:58proced. It says minority. It says

10:01everything.

10:02>> You're out of order. and you're going to

10:04have to be removed.

10:04>> If you're not interested in

10:05participating in the hearing, I'm going

10:07to respectfully ask you to leave.

10:08>> Um, I said I would participate. I just

10:10said I would like the vote to go and the

10:13vote will be staying the same, but they

10:15just don't want to do something easy.

10:17>> They want to do what they want to do.

10:18>> Miss Kley, I believe you're out of order

10:20and you need to be you need to either

10:22leave the thing or or you're wasting

10:24these people's time. We've all

10:26>> you're wasting their time.

10:27>> Is it your intent to move forward with

10:28the hearing or not?

10:30>> Not if they don't do the procedural

10:32thing correctly. We can't do anything.

10:34This is a special meeting, Miss

10:35Koviello, and it requires that we cannot

10:37add anything to the agenda.

10:39>> But do you understand that you are

10:40technically not ordering back and forth?

10:42>> Miss Coello, we're going to during this

10:45meeting until she leaves.

10:47>> I addressed I addressed your concerns.

10:51>> We're going to stick with the agenda. If

10:53it's not your intention to participate

10:55in tonight's meeting, let us know. Uh, I

10:58understand and respect your your

11:01position to advocate for what you

11:03believe is right, but we have to stick

11:06to the agenda. We have countless people

11:08who have taken time out of their lives

11:10for complaints that have pending for

11:11months, and I'd like to get them

11:13addressed.

11:16Thank you.

11:20>> Then I will leave and I will take this

11:23complaint up because bottom line, you do

11:26not have a minority. You do not have one

11:28Democrat and everyone here knows that.

11:32>> Your comments are noted.

12:05There will be an official complaint.

12:24All right. I'm sorry for the

12:25interruption. Um, and thank you for your

12:27time and your patience. Um, so we will

12:30we need to take a vote to seat um Sharon

12:34O'Brien in Miss uh Commissioner

12:37Kovello's um place and to seat Mike uh

12:43Karzanski in Mike Bunko's place as the

12:47um landlord.

12:49Uh so get a motion.

12:51>> I guess we'll start off. Uh I'd move to

12:53see Commissioner O'Brien in place of

12:56Commissioner Koviello.

12:59All

12:59>> that's the first one.

13:00>> Yep.

13:01>> Is there a second?

13:03>> Second.

13:03>> Second.

13:04>> All in favor?

13:06>> Any opposed?

13:08>> I So it passes.

13:09>> Second.

13:10>> Uh second. Move to seat Mike Krosanski

13:12in place of Commissioner Bunko.

13:16>> I have a second.

13:17>> Second.

13:18>> All in favor signify by saying I.

13:21>> I. Any opposed? Okay.

13:25Thank you so much. All right. Moving

13:29up.

13:31>> And chairwoman, just to be clear, we do

13:33have equal numbers of

13:35>> Yes. I'm the tenant and and um

13:39Commissioner Kranski is the landlord, so

13:41it's equal number and everyone else is

13:43neither landlord nor tenant.

13:45>> Understood.

13:46>> Okay. All right. Good evening, everyone.

13:49Um as chair, I want to take a moment to

13:51clarify the precise legal role and

13:53purpose of the Southernington Fair Rent

13:54Commission. Um, we often hear concerns

13:57regarding individual liberty, freedom of

13:59contract, and the private agreements

14:00made between landlords and tenants. It's

14:03vital to recognize that under um

14:06Connecticut law, fair rent commissions

14:08do not exist to strip away contractual

14:10freedom or rewrite private agreements at

14:13will. We respect the fundamental

14:15principles of uh contract law and the

14:18rights of property owners to earn a fair

14:21return on their investment. However,

14:23state statute CGS um 7-148B

14:27specifically empowers municipalities to

14:30create fair rent commissions to address

14:32a very narrow specific issue preventing

14:35harsh, ownorous or unconscionable rent

14:37increases. To be clear about our legal

14:40authority, we are not a rent control

14:43board. We do not set legal caps on rent

14:46across the town, nor do we dictate

14:48market prices. We do not invalidate

14:50valid contracts. Our statutory role is

14:53quasi jud judicial. We act as a local

14:56administrative body to evaluate specific

14:59individual tenant complaints based on

15:01explicit criteria laid out by state law

15:04such as property conditions, local

15:06market rates, and utility costs. We

15:09operate strictly within statutory

15:11limits. Our authority is limited to

15:13determining whether a spec specific rent

15:17increase is unconscionably excessive

15:19under the law and if so determining a

15:21fair phase in or adjustment. Our goal is

15:24not to interfere with the free market

15:26but to ensure that the bargaining power

15:28between landlords and tenants remains

15:31grounded in fairness, basic

15:33habitatility, and state law. We are here

15:36to serve as a neutral, fair forum for

15:38both parties.

15:40All right.

15:42With that in mind, um we need to we're

15:46need to take a vote to consolidate um

15:49all the open complaints involving the um

15:53housing complex and the property owner,

15:55the pyramid real estate group

15:58and the and the um

16:02and the property or owners. Correct.

16:05Should we vote? We need to do we need a

16:06>> Yeah, you need a motion.

16:07>> A motion. Okay. So, we need a motion to

16:09cons consolidate the cases of the P uh

16:14the property owners at Pyramid uh and

16:17and the Pyramid Real Estate Group.

16:19>> If I may through the chair, does anybody

16:21have any objection to consolidate all of

16:22the cases?

16:25Okay. I move to consolidate all 18

16:27cases.

16:29>> All in favor signify by saying I.

16:31>> I.

16:32>> Any opposed? Hi.

16:37>> What's that?

16:39>> Don't worry.

16:41>> Do we have to swear in all the parties

16:42first?

16:44>> Yeah. Yeah. We'll have loose swear in

16:45the parties. Sorry.

16:47>> Uh so who is speaking on behalf of the

16:50complainants? All right. Would you guys

16:52all mind standing up and raising your

16:54right hand?

16:55>> Uh who whoever intends on testifying at

16:57the

17:01>> just two of you. All right.

17:07anybody that intends on speaking

17:09>> or may speak

17:09>> or may speak.

17:12>> All right. Do you guys swear to tell the

17:13truth, the whole truth, and nothing but

17:14the truth? So, help you God.

17:17>> And then on behalf of the respondents,

17:21your anticipated witnesses.

17:23>> Yes. Um, I have here.

17:27>> You guys mind raising your right hand?

17:30You swear to tell the truth, the whole

17:31truth, and nothing but the truth. to

17:32help you God.

17:33>> I do.

17:34>> Thank you.

17:39>> We got a lot of evidence to say what's

17:43>> get it all.

17:44>> Yeah. Go ahead.

17:45>> I'm going to turn over to um Vice Chair

17:47Gotautlib.

17:48>> Evening everybody. So, we have a lot of

17:50evidence. I I don't know if anybody's

17:52had a chance to look at what each side

17:54has had, but instead of voting on

17:56everything one at a time, we've been

17:57provided with a copy of the the tenants

18:00binder, which we have, and we've also

18:02been provided with uh a copy of

18:04everything from the landlord side. Does

18:06anybody have any objection to all of

18:07that just coming in now, so that way

18:09we're not uh wasting time here?

18:13>> I have no objection. I don't haveies.

18:17>> Oh, we don't have any copies of their

18:21No. Okay.

18:31>> We have

18:32>> Yep. We can That That's what we're doing

18:33now. We're just We're We're giving each

18:35other chance to get your um evidence to

18:39one another.

18:41>> So

18:42>> otherwise, we're going to have to start

18:43voting on all pieces of evidence

18:45individually and

18:46>> y

18:46>> that's going to make for a long night.

18:54Yeah,

18:58>> I heard something about Dropbox.

19:00>> We could make the Dropbox available.

19:03>> We can make the Dropbox available.

19:04>> Yeah,

19:07>> here.

19:07>> Yep.

19:08>> Neither party received.

19:11>> They weren't shared. Okay.

19:34Okay.

19:39>> Can you say I'm sorry. I I don't know

19:41your name, sir. Again, if you could

19:42please just

19:50Okay. What was your question?

19:56>> They have copies.

19:57>> They have physical copies there.

19:59>> Yes.

20:11>> I have the drop box up if I need it.

20:23I have it on.

20:24>> I'll still give it to you.

20:25>> Okay.

20:26>> They can they can have my copy.

20:27>> Okay. Here we

20:36>> just took it.

20:38>> Here you can you can have mine.

20:54Just leave that there.

21:08Just for the record, I'll note that the

21:10complainants provided a copy of the

21:12exhibits to me, which I provided to all

21:13of the commissioners. Respondents also

21:16provided a copy of their proposed

21:17exhibits, which I shared with all the

21:20commissioners as well, but the exhibits

21:21were not shared between either party

21:23prior to this hearing.

21:27And there are multiple copies of the

21:30respondents exhibits still available on

21:32the table to my right.

21:41>> They do have copy.

21:55Does does anybody need time to review

21:57this

21:58>> before we get started?

22:01>> I mean,

22:03well, they just got yours as well, so

22:05it's kind of, you know, fair that

22:07everyone is just getting this at the

22:08same time.

22:09>> I'm confused. Also,

22:12do we know who prepared this?

22:15This right here that I just was handed

22:21made aware

22:23presenting this

22:26>> the people that were sworn in would be

22:28the people that are going to testify and

22:30present that as evidence.

22:33>> They

22:36>> you're you're you represented by

22:38council. You you're free to

22:40cross-examine

22:42>> everybody.

22:43>> So there there will be no back and forth

22:45between you guys. Everything comes

22:47through the chair. Okay, just to

22:49maintain order. Thank you.

22:51>> So, I'm I'm still I'm still my question

22:53remains.

22:55I want to know you know what the source

22:57is. There's no way that you know 29

23:00people got together.

23:02>> Yeah. Again, again, if I may through the

23:05chair,

23:05>> I need you guys.

23:06>> If I if I may through the chair, you

23:08have council. Council is entitled to

23:09cross-examine anybody that's providing

23:11testimony.

23:13>> So, as far as So, sir,

23:14>> this time I'm asking where this came

23:16from. This was provided by the 18

23:18complaintants that filed the complaint

23:23>> against the respondent.

23:25>> I'd like to know who

23:27>> I'm not I'm not asking whether or not

23:28that's sufficient for you, sir, but you

23:30have counsel. Council can cross-examine

23:32anybody that's going to be testifying.

23:34If you have questions, you can put that

23:36through your attorney.

23:36>> Got it. So, you will not answer the

23:38question.

23:39>> No, I'm not going to answer I am not

23:40answering that question. Thank you.

23:50You ready? Uh on behalf of the

23:53complaintants, uh whoever's up may come

23:54and testify.

23:56>> Are we giving?

23:57>> Uh to what?

23:59>> Oh, you're still my apologies.

24:02Your your witness made it seem as if he

24:04was done reviewing the documentation.

24:42stretch out.

24:47>> I'm okay with that.

24:54for

25:00that time.

25:12>> That's what I'm saying.

25:14>> Yeah, for sure.

25:30Yeah, this is some of the tenants side

25:33of things.

25:34>> That's all ten.

25:36>> This is all the Dropbox stuff.

25:37>> That's all.

25:38>> Yeah. So, I've got that here. I looked

25:40at it before, but this stuff is

25:42something different. Yes,

25:43>> that's the uh the tenants.

25:46That's the whole

26:34You were saying it

26:40wasn't

26:43You didn't know.

26:48>> Have all the commissioners have have

26:49time to review the documentation.

27:17But we're not

27:29>> commissioner question. Can I allow the

27:32evidence to come in as for ID purposes

27:34only like report and then

27:36>> can you come to the micro Can you come

27:38to the microphone because we have to

27:39have everything recorded.

27:40>> Yes. Excuse me. Hear me now please. Yes.

27:43>> Yes.

27:44>> Perfect.

27:44>> Uh can we admit the complaint's evidence

27:47for ID purposes only like in court and

27:50then if something comes up that I

27:51believe objectionable I can make the

27:52objection at a time when it comes into

27:54evidence because it's very difficult to

27:56go through such so many documents so

27:59fast. Does that make sense?

28:01>> I I I understand that. Uh um I would ask

28:05I would ask them if they have any issue

28:06with that uh the tenant side. If they

28:09don't, I would I'm okay proceeding in

28:11that manner and the record would just

28:13then reflect whatever was objected to or

28:16or not and we'd have to vote on it on a

28:18on a evidence piece of evidence by piece

28:21of evidence basis.

28:22>> So also I'm I'm unclear. I mean our our

28:24package I think it's very clear what

28:25we're using the documents for. A lot of

28:27this I'm just I'm unclear if it's

28:29relevant. I'm unclear what it's being

28:31used for.

28:31>> Yeah,

28:32>> we can do that as we

28:34>> we can there's

28:34>> the commission can do that as we go.

28:36>> It's a voluminous amount of evidence on

28:38both sides. So for efficiency purposes,

28:41the proposal is to let everything in. If

28:44there's an objection, yes. Y

28:46>> then, you know, we could certainly take

28:48that up if it's going to be for just

28:49identification purposes. I mean, we're

28:51not a court. It's a quasi judicial

28:53proceeding and not a full-on judicial

28:56proceeding. So, we can vote on it as

29:00needed. Uh the goal here is to be as

29:02efficient as possible with time because

29:05uh you know, we're probably going to go

29:06till about 10:00 tonight and we'd

29:08certainly like to be able to let

29:10everyone perhaps finish. Uh and if not,

29:14then we could always, you know, we might

29:16have to come back another day to

29:17deliberate.

29:19But they have somebody on there

29:21>> and excuse me, attorney attorney

29:24Matachio, do we need to have the um I we

29:27should have on the record the name of

29:29the people who were sworn in to speak on

29:31behalf of the tenants. Do we have their

29:33names?

29:33>> I'd recommend when they get up to speak,

29:34just have them.

29:36>> Sure.

29:37>> You You'll have to go up there, sir. If

29:38you have something to say.

29:39>> Well, it's But we didn't swear him in,

29:41so we have to This has

29:44>> He was sworn in.

29:44>> Were you one of the ones sworn in? Okay.

29:46>> He was sworn in.

29:46>> That's That's what I'm mean. I don't

29:48know who was sworn in. Yeah, when they

29:49they speak certainly get their names for

29:51the record.

29:51>> Very good. All righty.

29:53>> Sir, you can speak if you'd like and

29:55address that.

29:56>> We're the only thing we're addressing

29:58right now is if you have have had enough

30:00time to review the documents before we

30:02proceed.

30:07>> We're not through through the chair,

30:09please. Of

30:18course. Oh, of course. Of course.

30:20>> This gent this gentleman was asking a

30:22question. So, I was addressing that. If

30:24you'd like to say something, sir, you'd

30:26have to go.

30:26>> I'd have to go to the microphone.

30:28>> Please go up to the microphone and

30:29identify yourself.

30:31>> This brings us to a preliminary issue I

30:32think would be good to address right

30:33now. Um, I am familiar with this

30:35gentleman. uh he is he works with the

30:38DCP.

30:39>> We're we're not presenting evidence

30:41right now.

30:41>> It goes to whether he can present at all

30:44or testify.

30:46>> So that's why I think it's relevant to

30:48bring him now. Um I have asked the DCP

30:50and the attorney general to investigate

30:52whether Mr. Delaherryi

30:54is exceeding his statutory authority

30:56under the relevant DCP statutes by

30:59appearing at mobile home parks, fair

31:01rent commissions, testifying about what

31:03he perceives to be violations and other

31:05matters because he is a member of the um

31:09the mobile home advisory committee. uh

31:11>> we're going to be polite-

31:13>> which is um it it is governed by statute

31:17and I don't think he has the authority

31:20as a as as a representative DCP to be

31:23appearing at mobile home parks and fair

31:25rent commissions and testifying. I think

31:27it's a conflict interest and I did get a

31:29response from an attorney at DCP saying

31:32that they are currently looking into it.

31:33So I want I I also um provided the

31:37commission's council with a letter as

31:39well part of our record. So, I just want

31:40to make that very clear.

31:42>> Okay. We did we did recognize your

31:44concern. You sent that to us ahead of

31:46time. Um, but because that has not been

31:49adjudicated and there's no stay,

31:51correct?

31:53>> You don't have any judgment on that?

31:56>> Nothing.

31:57>> No, I do not.

31:57>> Okay. So, we have

31:58>> it's pending as I understand.

31:59>> Yes. So, we have to proceed.

32:01>> Okay. And I may have other grounds b um

32:05I don't know what this gentleman is

32:06going to testify to. So, I may have

32:07other objectional grounds as well.

32:08>> Okay. noted.

32:10>> All right, we we're not beginning

32:12official testimony. This just questions

32:13about procedural things.

32:16>> Uh you asked me to identify myself. I

32:17just wanted to talk. First of all, my

32:19name is Dave Delorey. I live at 43

32:21Riverside Drive here in Southernington.

32:23It's in the park across Route 10 um from

32:28Apple Valley, which is the subject of

32:29the complaints. I've been asked to speak

32:31on behalf of residents because although

32:34I do not work for DCP, I am a volunteer.

32:37I

32:37>> Okay, we're we're not we're not going

32:39into we're not addressing all this.

32:40>> You you asked when we were discussing

32:42evidence, you asked to be heard about

32:43something with

32:46he was asking about procedure.

32:47>> I think I wanted to re reiterate what

32:49Rebecca was trying to say is that if

32:51they are going to be able to

32:52cross-examine our witnesses, we have the

32:55same privilege.

32:56>> Oh, of course. And and also I just want

32:58to remind that this is that the fair

33:01commissions are a quai judicial

33:04authority but it is not a court of law

33:06and one of the one of the reasons the

33:08state creates the fair commissions is so

33:10that re residents can seek to agree

33:13themselves without having to go before

33:16courts of law.

33:16>> The only the only I asked you to come up

33:18to speak because there was a question

33:19with regard to procedurally with regard

33:21to evidence. We're not asking for

33:23testimony at this point in time. So if

33:26the concern is will they get the same

33:27right to object to evidence the answer

33:29is yes.

33:30>> Okay.

33:30>> You will. Okay.

33:31>> Yep.

33:32>> Thank you.

33:41>> So should we recess for them?

33:43>> No. Let's go.

33:44>> Yeah. Okay.

33:47>> This is in court.

33:55So, we're just going to give you a few

33:56more minutes. If you feel you need more

33:58time, let us know. Um, if you're if you

34:00feel you're ready, if we have, you know,

34:13>> so you can make an opening statement.

34:16You have the right, well, council is

34:19going to have the right to cross-examine

34:21anybody that's going to be testifying on

34:23behalf of the tenants. And I don't know

34:26if you're familiar with that, but they

34:27get to ask you questions. And the

34:30expectation is they answer the question,

34:32you answer the question, you'll give

34:33them an opportunity to finish their

34:35question. So that way we can have a

34:37clean record of the questions and

34:38answers that are being provided. So

34:41that's, you know, we can give you an

34:44both opportunity to have an opening

34:45statement. um through the chair, I would

34:48offer the the complaintants to go first.

34:50>> Yep. And then the complaintants will

34:52will go first. Um and I just want to,

34:55you know, remind you that you everything

34:57comes through me. There's no talking

35:00back and forth.

35:02Great. And we're going to maintain order

35:04and respect for each other. Thank you.

35:06So, are the are you guys ready? All

35:09right. So, we just need your you need to

35:12state your name and address for the

35:14record.

35:15Yes, my name is Tracy Miller. I live at

35:18217 Dunham, lot 17.

35:23All right, good evening everybody. My

35:25name is Tracy and I live at Apple Valley

35:28Village with my 10-year-old and uh it's

35:32it is a great place to be. I love all my

35:33neighbors. I'm speaking tonight on

35:35behalf of myself and alongside other

35:37residents who have filed fair rate fair

35:39rent complaints because this is about

35:42much more than a $50 rent increase. Our

35:45monthly land lease is going from $550 to

35:47600 plus an additional 12 for wellwater,

35:501417 for sewer, and $12 for trash. That

35:54brings our total monthly obligation to

35:56$638.17

35:58before any resident specific changes.

36:01That is an increase of $88.17

36:04per month or about 16%. The question we

36:08are asking the commission is simple.

36:09What are we receiving in return for that

36:11increase? We own our homes. Some of us

36:13have mortgages on our home as well. We

36:15pay our own taxes taxes and insurance.

36:18And under the park rules, we are

36:20responsible for for much more of the

36:21maintenance of our own lots. But we

36:24depend on the park owner for the land

36:25and the parkwide systems that we cannot

36:27maintain or replace ourselves. Residents

36:30have raised concerns about water

36:32reliability, hazardous trees, roads and

36:34drainage, snow and ice, common areas,

36:37emergency response, communication with

36:39management, and delays in correcting the

36:41problems. We are also now being charged

36:44separately for wellwater, sewer, and

36:46trash. Recycling is mandatory in the

36:48rules, but a recycling container has not

36:50been provided as expected, and the trash

36:53capacity is inadequate for the

36:55community.

36:56We are going to show you examples of how

36:58we are getting less for more money. We

37:00will show you uh how our privacy is

37:02being infringed upon. There's also

37:04additional fees and penalties that

37:06matter when considering what is what it

37:09actually costs to live here. Those

37:11include a reported $350 emergency line

37:14charge

37:16and other daily or event-based

37:18penalties. Residents should not be

37:20afraid that reporting a water failure,

37:22dangerous tree or electrical problem or

37:24other emergency could result in in an

37:27excessively large charge. We are not

37:29asking the commission to decide this

37:31based on complaints alone. We have

37:33brought leases, notices for photo

37:36photographs, water records, rules,

37:38bills, and others other documentation so

37:40the commission can look at what the

37:42residents are paying and compare that

37:45with the services and conditions we are

37:47actually receiving. We understand that

37:49owning and operating a manufactured home

37:52community costs money. We are not saying

37:54the rent can never increase, but over

37:56the two years it has increased

37:58excessively. We are asking whether this

38:00increase is fair given the total amount

38:02residents are now being required to pay,

38:04the services being provided, the

38:06condition of the park, the repairs that

38:08remain necessary, and the amount of

38:09maintenance residents themselves are

38:12already responsible for. We are asking

38:14the commission to look at the whole

38:16picture, not simply the8 $88.17

38:19in increase in base rent. This is why

38:22we're here tonight.

38:24Unlike apartment buildings, we rent we

38:26or rented houses, we own our homes and

38:28rent the land that we reside on. When

38:30the land lease increases, we can't just

38:32pack up our things and find lower rent.

38:34We would have to move our homes. And

38:35when your home doesn't have axles,

38:37wheels, or a tow hitch, it creates a

38:39very difficult and costly situation.

38:42First, I want to apologize that we will

38:43be referring to many different documents

38:45inside of one lease package. upon each

38:47lease renewal, especially this most

38:49recent one. The lease agreement refers

38:51to all documents and amendments issued

38:53in past years. This makes understanding

38:56the current lease agreement and

38:57associated documents very difficult. You

39:00will also see in our in your binders a

39:02few examples of pyramid issuing leases

39:05less than one year and the residents did

39:07not request the leases for less than one

39:09year. Land lease. As stated, our monthly

39:12land lease is going from 550 to 600 in

39:14base rent, plus an additional 12 for

39:16wellwater, the 14 for sewer, and 12 for

39:18trash. These fees were previously

39:20included in the monthly rent. That

39:22brings the common monthly obligation to

39:24638. That's roughly a 16% increase.

39:27Pyramid's letter to residents dated June

39:301st states that Dunham lots have been

39:32historically low and low in comparison

39:34to the other parks that we have

39:36surveyed. Now, Pyramid is going to talk

39:38about other comparable mobile home parks

39:40in CT, but these parks aren't even local

39:42and they aren't even loc located in

39:44Harford County. The residents of Apple

39:47Valley have also surveyed other parks in

39:49the area, and we've we have found that

39:50Pyramid has been historically high in

39:52comparison. In your binders, you will

39:55see two comparable parks which charge

39:57their residents less per month with

39:59water, trash, and sewer included. One is

40:02Liberty Mobile Home Park in Planeville.

40:04Their amenities are very similar to

40:06ours. Their land use lease includes

40:08water, even though it's public water and

40:09not well water, sewer, trash, ground

40:11maintenance, snow removal, and

40:13management. Their land lease is $475.

40:16Another is Riverside located in Bristol.

40:19Their amenities are also the same as

40:20Liberty Mobile Home Park. Their monthly

40:22land lease is $479.

40:24Then we move to the Sun Communities,

40:26which are 55 plus mobile home parks.

40:28They have more amenities than we have.

40:31They each have a clubhouse with

40:32community activities, a community pool,

40:34curbside trash and recycling pickup,

40:36ground grounds maintenance and

40:38management. Their monthly land lease

40:40ranges from 633 to 678. Over the past 2

40:44years, Pyramid has increased the land

40:46leases substantially, unlike years

40:48before. We're going to start 2018 to

40:512019 was 445.

40:542019 to 2020, 458.

40:573% increase. 2020 to 21 465 2%. 2021 to

41:0322 another 3 brings us to 480. No

41:06increase from 22 to 23 but 23 to 24

41:10another 3% bringing us to 4.95.

41:13204 to 25 was another three increase 3%

41:16increase. 510 was our rent. 2025 to 26

41:20an 8% increase which brought us to 550.

41:23and now 26 to 27 with the 16% increase.

41:27We're at 637.

41:30There are a few leases, probably more

41:32over the years, that were written for

41:33less than a year and residents did not

41:34request shorter leases. Um, the lawn

41:37lots and lawns, we pay our our own taxes

41:40and insurance, and under the park rules,

41:42we are responsible for all the

41:43maintenance of our homes and much of the

41:45maintenance of our rented lots. We are

41:47required to keep our lot sites in a

41:49clean, well-kept, and attractive

41:50fashion. As stated in our lease, we are

41:53required to maintain lawns, flowers,

41:54shrubs in an orderly, trimmed, and

41:56well-watered manner.

41:58Although there they aren't any specifics

42:00listed on the requirements of these

42:02rules, this leaves it open for

42:03interpretation for Pyramid to send

42:05letters threatening to charge residents

42:07fines.

42:08In regards to lots, many residents don't

42:10know where their lot lines are. Most of

42:12us have never been told by Pyramid where

42:14our lot lines are, and in some cases,

42:16it's not clear either. We would like

42:18Pyramid to come out and establish lot

42:20lines on the property for resident

42:22clarity decks. We are also responsible

42:25for the maintenance and full replacement

42:26cost of our decks and stairs on our

42:28lots. One resident was told by Mary

42:32Heberger that leveling and repaving of

42:34their driveway was a res resident's

42:36responsibility. You will find that email

42:38in binders in tab 8. Fines and fees.

42:41While we're on the topic of fines and

42:43fees, there are also many examples of

42:45threatened fi fees and fines included in

42:48your binders. One is the emergency calls

42:50to Pyramid. In that letter the residents

42:52received on January 26, it states,

42:54"Please be advised that while Pyramid

42:56does not have an emergency call line

42:58that goes to our answering services

42:59after hours, this is reserved for true

43:01emergencies. This is also a fee service

43:04for which the person calling gets build.

43:07There's a $350 charge for the call in

43:09the first hour and additional fees for

43:11time spent on any issue beyond that. So

43:14even though residents are required to

43:16report to management any unsightly or

43:18unsafe conditions that they observe in

43:20the mobile home park, we can expect

43:22being fined in doing so. Their emergency

43:24line isn't monitored 24/7. During a

43:27storm on Friday, August 7th, a resident

43:29in the park had a tree fall on their

43:30home. The resident called the emergency

43:32line and couldn't speak to a per

43:34couldn't get a person to speak with. It

43:36was an automated AI generated phone

43:38line. He left several messages and no

43:40one called him back. This emergency

43:42protocol is not adequate. On March 11th,

43:45an email was sent to all residents

43:47regarding notice of lot maintenance

43:49violations. In this email, the letter

43:51states sections and rules and

43:52regulations and also say, "I will not be

43:54sending warnings other than this one.

43:56Fines will be automatic and continue

43:59until you email verifiable photo proof

44:01that cleanup has taken place. Now, some

44:04residents don't have email. This email

44:06was so intimidating and threatening that

44:07some residents went outside in the

44:09pouring rain to remove shovels and

44:11winter items off of their lots in fear

44:12of receiving fines on their accounts.

44:15Lease renewal fees. In the lease renewal

44:18dated June 1st of 26 uh 2026, residents

44:21are threatened daily fines if signed

44:23leases aren't returned by June 30th and

44:25states that residents will lose any

44:27protections that are included in the

44:29lease. These protections are directly

44:31related to the authority of the fair

44:34rent commission. Residents are also

44:36threatened daily fines for not

44:37submitting proof or of carrying Dunham

44:40mobile park home or prem. I'm assuming

44:43it's an insurance. Yep. Residents with

44:45oil tanks are being charged an

44:47additional $25 um a month for tank

44:49insurance. Some residents have requested

44:51copies of this tank insurance policy,

44:53but Pyramid has yet to prove a uh

44:55provide a copy. Water reliability.

44:58To start off this section, I will begin

45:00with one with our concern regarding

45:02management, communication, and

45:03accessibility. There have been several

45:05disruptions of water service just over

45:07the se past 7 months alone. 15 extremely

45:10low water pressure. 16 notified by

45:13Pyramid that there was a broken water

45:14pipe underground and water would be off

45:16from 2 to 5. 24 extremely low water

45:20pressure notified Pyramid water at

45:22vacant unit was turned off under mobile

45:24home behind the skirting. 318 received

45:26an email from Pyramid that the water

45:28would be shut off Friday 320 to replace

45:30an underground tank. 320 received an

45:33email stating that the water would would

45:35be off that evening from 9 to 11:00 p.m.

45:387:27 lost water during um a storm.

45:41Several residents called and emailed

45:42Pyramid. We were told to contact our

45:44property manager, Mary. This was at 3:45

45:47p.m. Several several of us left messages

45:49and emails for Mary and her assistant.

45:51We received an email back at 4:23 p.m.

45:53Pyramid stating that they received the

45:55calls and had a well pump guy and

45:57electrician on the way to fix the well.

45:59Pyramid has failed to maintain an

46:02adequate wells water system.

46:03Furthermore, despite receiving multiple

46:05recommendations from the DPH over the

46:08past several years, they have neglected

46:09to connect the system to the town's

46:11water supply, the trees. In the rules

46:14and reg regulations and aesthetic

46:16standards, it states that the park is

46:19responsible for maintaining and pruning

46:20of large trees and large shrubs. This

46:23hasn't been done until recently, August

46:252026. Pyramid is going to talk about how

46:27much they've spent the past few months

46:29on tree debris removal from the Fourth

46:30of July storm, but Pyramid had

46:32maintained and the pruning and

46:34inspection of the trees on the property

46:36for the past 11 years of owning the

46:37park. Some of these trees would have

46:39been removed prior to the storm. As a

46:42result of this negligence, one homerer

46:44one homeowner has lost her home

46:46completely due to a rotting tree falling

46:48on on other trees around it. We have

46:50included in our binder some of the

46:51photos of the dead and rotted trees that

46:53have fell on the property during the

46:54storm. The only tree that Pyramid has

46:56cut down since they've owned the park is

46:57a tree that was located on the lot above

47:00our water well location. Only recently

47:02has Pyramid trimmed the lower half of

47:04these trees on the property due to the

47:06requests of in the ongoing DCP

47:08investigation at the park. We would like

47:10to see the arborist reports that um

47:13Pyramid has obtained.

47:15Recycling and trash per the rules,

47:17regulations, and aesthetics on page 8.

47:19Recycling is mandatory but a recycling

47:22container has not been provided and as

47:24indicated and the trash capacity is in

47:26inadequate for the community. The rules

47:29indicate that we are supposed to provide

47:31we are supposed to be provided with a

47:32large blue p plastic bin but no one has

47:35ever ever received one. Frequently the

47:37trash receptacles are overflowing with

47:39garbage. Pyramid does not have a

47:41maintenance person on site so they don't

47:43monitor the trash recepticles. We have

47:45provided photos in the binders of the

47:47dumpster areas as well. snow removal.

47:50The lease package doesn't detail any

47:52park owner specifics when it comes to

47:53snow removal. The park's snow removal

47:56contractor comes and goes without any

47:58specific time frame, so residents never

48:00know when the roads will be accessible

48:02or when to clear our own driveways and

48:03sidewalks. Many times, residents clear

48:06their driveways only to be plowed back

48:08in by the contractor.

48:10The drains located on the property are

48:12never cleared by the contractor, so ice

48:14forms and clogs the drains. Then we get

48:16even more water and ice issues on the

48:18roadways and the driveways. We would

48:20like pyramid to establish guidelines on

48:22future snow removal. Common areas behind

48:25one of our dumpsters. It is a grown it's

48:27overgrown with weeds, poison ivy, and

48:29Virginia creeper. The lawn contractor

48:31has never cleaned up this area and

48:33poisonous weeds are intruding into the

48:34fenced in larger garbage area. On the

48:37property, there are weeds overtaking an

48:39electrical pole. This has never been

48:41maintained by the park owner. The folder

48:42is also in the binders. Binder section

48:44one park owner responsibilities and park

48:48and the park owner is responsible to

48:50keep any exterior area of the park not

48:53the responsibility of each resident free

48:56from any species of weed plant

48:57overgrowth which is noxious and

48:59detrimental to the health of the

49:00resident. There are also several

49:03residents who have mice and rodent

49:05issues on property and according to the

49:06rules and regulation standards. The park

49:08owner is responsible for the

49:09extermination of any insect, rodent,

49:11vermin, or other pests dangerous to the

49:13healthy of the residents. The park

49:15owners don't have a pest company

49:16regularly to visit or treat the

49:19property. There are many common road

49:21areas that are damaged in our need of

49:23repair and replacement. Pyramid has

49:25neglected maintaining the common areas

49:27since they have purchased the property.

49:29On July 4th, we had a serious storm hit

49:32our neighborhood. We had several trees

49:33and power lines down. The driveway into

49:35our park was not passable for a few

49:37days. It took Pyramids uh tree crew five

49:41uh 5 days to arrive on site and start

49:43cleaning up the trees and debris. One

49:45resident needed to be removed by

49:47stretcher for an a medical emergency.

49:49The firemen and EMT were were able to

49:52get onto the lot from a passageway

49:54leading from the school next door. Some

49:57residents received Amazon deliveries and

49:58Door Dash deliveries, but Pyramid's tree

50:01crew wasn't able to start removing

50:02debris until 5 days after the storm hit.

50:05Tree debris wasn't completely removed

50:07until 9:14. As of today, there's still a

50:10pile of wires that remain on the

50:11property as well. In this storm, our

50:13park entrance sign was also damaged. It

50:15has not been replaced.

50:18Retaliation. Residents are very

50:20concerned about the park owner

50:22retaliating. Some of us are already

50:23aware of the park owner's retaliation

50:25against a resident who was the first to

50:27file a fair rent complaint in June 2026.

50:30To address some of our concerns, we

50:31request that the park owner remove a

50:33section of the rules and regulations

50:34dated March 19 uh 18, 2026.

50:38Entry may also be made into a resident

50:40or tenants's mobile home to inspect,

50:42maintain utilities, to inspect or ma to

50:44make ordinary necessary or agreed

50:47repairs, decorations, alterations, or

50:50improvements to the mobile home to

50:52supply necessary and agreed to services

50:55or to deliver parcels that are too big

50:57for the mail facilities. All of all shut

51:00offs for our homes are located outside

51:02of our homes. Therefore, there's no

51:04reason for Pyramid to ever gain access

51:06to our homes. If an emergency arises,

51:08pyramid can shut off utilities from the

51:10exterior. In closing,

51:13I think we have done our due diligence

51:15in pro in proving that this rent

51:17increase is is excessive and

51:18unconscionable in comparison to the

51:20services provided. What are the

51:22residents of Apple Valley Village

51:24receiving in return for such an

51:26excessive increase? We are getting less

51:28and paying more money for it. These

51:30examples show the lack of maintenance by

51:32the property uh park owner and their

51:34negligence in operating the park.

51:40Thank you.

51:40>> Thank you.

51:45>> Attorney Shankle

51:47>> Shenko do so I can clarify something.

51:53>> Was that an opening statement? Are we

51:55doing opening statements? Opening

51:56statement. Okay.

51:59Okay, thank you commissioners. Thank you

52:01for everyone who's here. Um, that was a

52:04lot to digest.

52:06I'm Edward Shankle. I'm an attorney. I

52:08represent the landlord

52:10and

52:12we are here tonight in response to a

52:14number of complaintants and their fair

52:16commission complaints. Now, that

52:19presentation said a lot, but two

52:20takeaways

52:22that I heard stuck out with me. Number

52:25one, she said she was happy there. And

52:27number two, she said to consider the big

52:29the big picture, the full picture. Okay,

52:32I think it's very important that the

52:35commission consider the full picture

52:37because I have been in a number of

52:39instances in my career as an attorney. I

52:42don't have that much gray hair, but I do

52:43have about 20 years experience where

52:44I've been on both sides of cases.

52:47Sometimes it's one party verse a lot.

52:51Sometimes I'm the attorney with that

52:53group versus the one. And what I've

52:56admired from judges in the situations

52:58like this is when they could see the big

53:00picture, do not make an inference about

53:03numbers and see the facts, see the

53:06evidence, and hear the witnesses. Okay?

53:08And I think when you see the big picture

53:10and you hear the evidence and the facts

53:13and the witnesses and all the testimony

53:16and everything is considered, you will

53:18see that the rent increase from 550 to

53:21638 is more than justified.

53:25You are going to

53:26>> quiet.

53:29They did not interrupt you. You will not

53:31interrupt them. Am I clear? Thank you.

53:37You're going to hear from, in addition

53:39to myself, Peter Gray, who is the owner

53:42of the park, and Carl Emmondola, who's

53:44the head of maintenance.

53:47You're going to hear

53:49their testimony. We've also submitted a

53:52number of exhibits and a memo. We have

53:54financial documents including income and

53:56expense statement from 2021-25.

53:59We have provided all the backup, the

54:01invoices available. So, we are being

54:03very transparent about all of the money

54:07that the landlord has invested in the

54:08deferred maintenance and the capital

54:10improvements. That's exhibit B. Exhibit

54:13C is all of our comparables.

54:16And we believe there are many

54:17comparables that demonstrate that the

54:20638 is at or below market rent for

54:23similar lots.

54:26In an effort to be very transparent, we

54:28provided our tax returns from 2021 2025,

54:32which more or less matches the income

54:34expense uh statement from exhibit A.

54:37Exhibit E, we provided our response to

54:40the DCP complaints that some of these

54:44complaints have also made to DCP.

54:47Exhibit F and G are various Zilla

54:50documents about comps. Exhibit H is a

54:52map of Liberty Home Mobile Park, which

54:54is appears to be the primary comp that

54:56the tenants are relying on, and it will

54:58show that that is not a good comp at

55:00all. Exhibit I is a map of Donna Mobile

55:03Home Park. Exhibit J is another ZIL

55:07document pertaining to Wallingford,

55:09Connecticut, because some of the comps

55:11that tenants are using are from

55:12Wallingford, which demonstrate that

55:14Wallingford is not a good comp town.

55:17Exhibit K, L, and M are maps of the

55:21three mobile home parks that in

55:23Wallingford that the tenants are

55:25asserting are valid comps.

55:29By way of background, the owner of this

55:32park who's sitting behind me is not some

55:36part of some huge national company. Um,

55:39this is not one property out of

55:41thousands like some of these owners of

55:43mobile home parks in Connecticut.

55:45Mr. Gray is part of a local familyowned

55:48business. They invest in real estate in

55:51Connecticut.

55:52They take pride in all of their

55:54properties and many of them they've

55:56owned for many years.

56:00Moreover,

56:02a number of the properties that they

56:03purchased years ago have not turned out

56:05to be very profitable. But you know

56:06what? They have stuck with it and

56:08they're dedicated to improving the

56:10properties, improving the communities

56:12that they invest in. And actually this

56:14property is one of them.

56:18The financial evidence will demonstrate

56:20that the net loss

56:23the net loss in the last 5 years of

56:25Dunham a mobile home park is $363,520

56:31net loss. Despite that loss, the

56:34landlord has still invested hundreds of

56:37thousands of dollars in capital

56:39improvements, deferred maintenance, all

56:41in an effort to improve the park and

56:43make it a better community. The evidence

56:45will also demonstrate that the park has

56:47gradually improved over the years. And

56:49although Mr. Gray and his family are

56:51losing tremendous amount of money, the

56:54park is becoming a better place slowly

56:57but surely.

57:00Virtually all of the revenues that are

57:03derived from the park are reinvested in

57:05the park. Hundreds of thousands of

57:08dollars again have been lost. But any

57:11any revenue that was derived was

57:13reinvested in the park.

57:17The evidence will also demonstrate the

57:18operating expenses, taxes, insurance,

57:21sewer, water, everything has remained

57:23high and it has increased substantially

57:25over the years.

57:28The evidence will also demonstrate, as

57:30noted before, that when you look at

57:31valid comps both in Southernington and

57:34in comparable parks outside of

57:36Southernington, the fair market rent is

57:40the 638 is either at fair market or

57:44it's lower than other comps.

57:47And mobile home parks are not everywhere

57:50in Connecticut. And if you look at the

57:51toolkit that was put out by the judicial

57:54the um the court, it states and it's

57:57just cited in my memo that I submitted

57:58with the evidence that the commission is

58:00allowed to look at other towns for

58:03comps. And that is why I have cited

58:05other comps. And what's very

58:07interesting, one of the comps, which

58:08I'll get to in my main presentation, um

58:11some of the comps are from Brford,

58:12Connecticut, which I think even though

58:14it's about 20 25 minutes away, it's a

58:17very similar town. The comps are very

58:19similar parks and one of them actually

58:21just went through a fair rent commission

58:22hearing which decided that at a very

58:24similar park and a very similar town

58:26with very similar medium income, similar

58:29average home prices, similar average

58:31rents, 644

58:34was not what 644 was fair and equitable.

58:38That's where they came down. Notably

58:40638 here is lower. Okay, we'll get to

58:44that in the main presentation.

58:48a little bit more about the financials,

58:50which we'll get to in more detail.

58:54If you tally up all the taxes,

58:56insurance, professional fees,

58:58maintenance fees, and capital

59:01improvements

59:04since 2020, between 2021 2025, over 1.5

59:09million has been invested in the park.

59:10That's a huge number.

59:13Just maintenance and capital

59:14expenditures were $557,400.

59:20All the backups there, all the evidence

59:22is there.

59:24This is fact.

59:27Massive investments have been made

59:29despite huge losses.

59:32Just about any other landlord probably

59:33would have sold the park or repurposed

59:36it, but the Gray family is committed and

59:38dedicated to making this park better,

59:40and it has become better.

59:46Now I acknowledge that and my client

59:49acknowledges it's it's just math that

59:51this last pass increase was a higher

59:54percentage increase in the previous four

59:56years comes out to about 16%. In the

59:58previous years, there has been a lower

1:00:01percentage increase. As noted and as we

1:00:04demonstrated by the evidence, this is

1:00:05justified because of all the the massive

1:00:07expenses and the losses that the

1:00:10landlord has had over the years. And

1:00:13they're entitled to at least someday

1:00:14make a profit and to continue to make

1:00:16the park a better place. But here's an

1:00:19important mathematical fact. If you

1:00:22actually average the increases over the

1:00:25last five years, you get to 5% about

1:00:28five six% a year.

1:00:32Is that unreasonable?

1:00:34I don't think so.

1:00:38Now there was a number of complaints

1:00:42raised by the the the the opening

1:00:44statement of um the complainant

1:00:47about a number of things

1:00:51as an initial point and this is actually

1:00:54important thing that the commission

1:00:56should probably decide as part of this

1:00:58hearing.

1:01:00The complainants have als or some of the

1:01:02complaints have also submitted these

1:01:04same complaints

1:01:06about allegations of the trees not being

1:01:10trimmed properly or there's water

1:01:12accumulation here and there or they

1:01:15think the fines are not proper to the

1:01:17DCP.

1:01:19Now, by statute, this commission has the

1:01:21authority to determine if there's

1:01:23violations of regulations and statutes

1:01:25and and that relates to the rent, and

1:01:28you can make orders about corrections of

1:01:30those what what you perceive to be

1:01:32violations if there's an order by this

1:01:34commission. Now, the DCP is already

1:01:38kneedeep in this. They have provided

1:01:41they've done an investigation. I have

1:01:44submitted as exhibit E a 21-page

1:01:47response uh with evidence to DCP which

1:01:50the landlord adamantly denies there's

1:01:52any violation. Uh there's been no

1:01:54finding of any violation as a response

1:01:56to those complaints and so it's all

1:01:58pending before DCP now and I leave it to

1:02:01the commission discretion. Um but if

1:02:05we're also going to hear evidence about

1:02:07alleged violations, it's it's

1:02:08duplicative. It's duplicative. So, I

1:02:11just want to raise that point and put it

1:02:13out there. Um, exhibit E, I urge you to

1:02:16peruse through. It's it's very thorough,

1:02:19but I want to briefly summarize it.

1:02:22And this is going to hit some of the

1:02:24points that uh the complainant raised in

1:02:26her opening statement.

1:02:29There was allegations that the tree

1:02:31trimming and removal was was um not

1:02:36sufficient.

1:02:38Well,

1:02:40that's unfair characterization because

1:02:42any pictures that were submitted to the

1:02:44DCP, which are also submitted as part of

1:02:47these complaints, were actually a

1:02:49snapshot of an ongoing and serious

1:02:52emergency emergency situation resulting

1:02:54from very severe storms in July.

1:02:58Many trees were damaged at no fault of

1:03:01my client, no fault of the tenants, no

1:03:03fault. It was a storm. It was a massive

1:03:04storm and there was massive damage and

1:03:08the landlord acted promptly

1:03:11and prudently and hired a very skilled

1:03:15arborous team at humongous expense,

1:03:19$80,000

1:03:21to act quickly. And they removed 23

1:03:23trees. Again, they removed 23 trees and

1:03:27they trimmed between 60 and 80 trees as

1:03:30well, the limbs. This was an ongoing

1:03:33process process took weeks and it was

1:03:36very skilled. It was very difficult and

1:03:38it was an emergency. And so any

1:03:42complaints that were made during this

1:03:44process while the landlord acted quickly

1:03:48impromptly and spent a lot of money is

1:03:49just an unfair characterization.

1:03:52Part of exhibit E that was submitted to

1:03:54the DCP is actually the arburish report.

1:03:57One of the tenants mentioned um she

1:03:59wanted to see the arberish report. It's

1:04:00exhibit E and the materials

1:04:03there. We have a licensed arborist who

1:04:06attested to the facts I just mentioned

1:04:08and inspected every single tree on the

1:04:11property and certified that it's now

1:04:12safe.

1:04:14Now, there's also mention of a tree

1:04:16damaging one of the mobile homes. Okay,

1:04:20this is actually

1:04:22a fact that shows what type of landlord

1:04:25my client is. There was a tree that fell

1:04:28on a mobile home. It was damaged

1:04:31severely and created a very serious

1:04:33safety hazard for the park because

1:04:35there's children there. There's, you

1:04:38know, obviously adults, but particularly

1:04:40children, a damaged mobile home that has

1:04:45openings that a child can climb into.

1:04:47That's a very serious situation.

1:04:50So, my client through counsel attempted

1:04:52to contact the owner to secure it, make

1:04:55it safe.

1:04:56fix it, remove it, whatever had to be

1:04:58done.

1:04:59Those efforts weren't successful. So,

1:05:03the landlord went above and beyond its

1:05:06obligations to make that area safe and

1:05:10purchased that mobile home for the

1:05:12purpose of making it safe and securing

1:05:14it because the tenant was either

1:05:16unwilling or unable to do so at great

1:05:18expense to my client.

1:05:21So, while some of the tenants have

1:05:24chosen to take a snapshot of an

1:05:26emergency situation and say that the

1:05:29landlord is not doing its job, again, to

1:05:33the complainant's point, you got to look

1:05:34at the big picture. When you look at the

1:05:36big picture, you take a step back and

1:05:38look at everything.

1:05:40The landlord did everything it was

1:05:42supposed to do and went well and beyond

1:05:45its call and what it's obligated to do.

1:05:48Okay? And again, I mentioned this

1:05:50before, the skilled arborist team cost

1:05:53$80,000.

1:05:55That was a bill that was paid in a short

1:05:57period of time for any landlord. That's

1:05:59a lot of money. My client paid it

1:06:01promptly to resolve an emergency

1:06:03situation.

1:06:06There were also complaints about the

1:06:09water pressure. Mr. Aandola can testify

1:06:12about that in a moment.

1:06:14One water pressure incident was caused

1:06:16by a nearby lightning strike and that

1:06:18was resolved within a matter of hours.

1:06:20One or two hours. Mr. Amdulla can can

1:06:22tell you exactly the other water

1:06:25pressure issues

1:06:27that resulted from water main repairs.

1:06:30Again, we're talking one or two hours.

1:06:32Mr. Amando will tell you all about that.

1:06:34This is very insignificant. And again,

1:06:37when you look at the big picture, the

1:06:39landlord did everything it was supposed

1:06:41to do to quickly, promptly, and

1:06:43prudently resolve the issue.

1:06:47Trash. We can talk about that when we

1:06:49get to the main presentation.

1:06:52The evidence will show that in previous

1:06:56years, there have been no issues with

1:06:58the dumpster recycling bins. Nothing.

1:07:02And the last year, for one reason or

1:07:04another, there's been some complaints.

1:07:06But if you look at the pictures and you

1:07:08look at the evidence, this is actually

1:07:10because there there's overage and and

1:07:13and trash piling up because the tenants,

1:07:17with all due respect, are not folding up

1:07:19their boxes. They're throwing out

1:07:20furniture. They're doing things that

1:07:22they're not supposed to do. And this

1:07:24actually is inconsistent with D

1:07:26guidelines. And if all tenants followed

1:07:30those guidelines, broke up their boxes,

1:07:32didn't put furniture in the dumpster,

1:07:34and followed the rules, we wouldn't have

1:07:36this problem.

1:07:41Road repairs. I don't know if any of you

1:07:43have gone to Dunham Mobile Home Park. I

1:07:44I encourage you to go there, drive

1:07:47through there. I did it today.

1:07:49>> I did.

1:07:50>> The roads are are fine. I mean, you

1:07:54know, is there a crack here, a crack

1:07:55there? you know, normal wear and tear.

1:07:57They're fine. They are prudently

1:07:59maintained. And you can actually see,

1:08:01and this is also in exhibit E, which is

1:08:03submission to the DP,

1:08:05where the landlord made repairs. The

1:08:08landlord made a lot of repairs to the

1:08:10road network. Okay? So, there's evidence

1:08:13in the package that the landlord is

1:08:15doing what it's supposed to do to repair

1:08:17the roads. Okay?

1:08:20So, we respectfully submit that there's

1:08:22no violation of any road repair

1:08:24ordinance. Um, and the roads can easily

1:08:27be traversed and there's nothing wrong

1:08:29with them.

1:08:31In the opening statement of the

1:08:33complainant, there's also mention of

1:08:34snow removal.

1:08:36This is also a common theme in the

1:08:38complaints in the DCP complaints.

1:08:42You know, we live in New England and my

1:08:45client doesn't do the snow removal in

1:08:48house. It's a contractor and I think a

1:08:51lot of these complaints are about the

1:08:53timing of the snow removal

1:08:56and unfortunately snow starts and stops

1:08:59at inconvenient times and sometimes

1:09:01you're waiting for the snowplow truck to

1:09:02get there and just doesn't happen the

1:09:04moment that you want to. I I've been a

1:09:06tenant at numerous buildings where

1:09:08that's the case and it's just, you know,

1:09:11it's part of living in New England. The

1:09:13snow contractor gets there as fast as

1:09:15possible, does a prudent job plowing all

1:09:18the snow,

1:09:19and the plow is done in accordance with

1:09:21industry standards.

1:09:23With that said, the manager is currently

1:09:26talking to the snowplow company company

1:09:27to see if there's any way to improve the

1:09:28process. Okay. So, we're working on

1:09:31that, too.

1:09:37In some of the complaints, there was

1:09:39issues raised about um the requirement

1:09:42that the landlord be named as an

1:09:44additional insured in their homeowners

1:09:46policy. This is very standard and in

1:09:49fact it does not result in any increase

1:09:52on the tenants. It doesn't it doesn't

1:09:54result in any increase in cost on behalf

1:09:56of the tenants.

1:09:59So it shouldn't be an issue and it's

1:10:01very standard.

1:10:04the fines.

1:10:07So,

1:10:08there are provisions in the rules that

1:10:10allow for fines for violations of the

1:10:12rules. This is permitted by law. This is

1:10:15common at many mobile home parks.

1:10:18Currently, it's $25 a day.

1:10:21Some of the complaints have asked the

1:10:22DCP to review that, which is fine. That

1:10:26is their right.

1:10:28There is case law which I cited in my

1:10:31DCP response in exhibit E

1:10:34which admittedly is not directly on

1:10:37point. It's very strong persuasive

1:10:39evidence though and I I submitted this

1:10:41to D. There's a case about a condo

1:10:44association that had $25 a day fines for

1:10:47rule violations and the court upheld

1:10:48that. I think there was two cases I

1:10:50cited in the DCPU complaint. So, I

1:10:52provided that those cases to the DCP

1:10:55attorney and she's reviewing it.

1:10:58With that said, if the DCP determines

1:11:00that those fines should be reduced or

1:11:03changed,

1:11:05the landlord would do that.

1:11:08The landlord and I believe as well that

1:11:12in terms of the fines, there's nothing

1:11:15there's nothing unusual about these fine

1:11:17provisions. They're they're they're very

1:11:19similar ones in other mobile home parks

1:11:21throughout the state. And it's not a big

1:11:24money. The purpose is not to make money

1:11:26on it. Um it's really just to maintain

1:11:30the aesthetic standard of the park.

1:11:32Again, the Gray family is committed and

1:11:34dedicating to improving this park. If

1:11:37they weren't committed and dedicated,

1:11:38they would have bailed ship 10 years ago

1:11:40and sold to a hedge fund. But they're

1:11:42committed. The rules, the fines, they

1:11:46serve a purpose. It's all processed to

1:11:49keep the park nice and clean and orderly

1:11:52and aesthetically pleasing. And that

1:11:55matters. It, you know, when when a park

1:11:57is is aesthetically pleasing, it's

1:11:59clean. It attracts better tenants. It

1:12:02keeps the animals away. It it attracts a

1:12:05better community. Everyone's happier.

1:12:07So, these rules serve a purpose. And the

1:12:09fines are not meant to bully anyone or

1:12:11make money. It's just to it's just to

1:12:14serve that purpose. And again, they're

1:12:16very common throughout Connecticut. Now,

1:12:18one thing I also want to correct from

1:12:19the complainant,

1:12:21there was a representation that there's

1:12:23a $350 fine for using the emergency

1:12:26line. That is not true. I don't know if

1:12:29there was a miscommunication or a

1:12:31misunderstanding or some anywhere in

1:12:33between. The tenants can call the

1:12:35emergency line whenever they want. They

1:12:37could also call 911. That's actually a a

1:12:40very useful emergency line, always

1:12:42available.

1:12:44Um, there is no penalty for using the

1:12:48emergency line. What there is a penalty

1:12:50for is misuse of the emergency line

1:12:53because and there's a valid reason for

1:12:55this. Years ago, I don't know if the

1:12:59tenant these tenants are still here or

1:13:01not, but some of the tenants were

1:13:04calling the manager the the the

1:13:07emergency number non-stop during the

1:13:10night and it was in bad faith. They were

1:13:13not emergencies.

1:13:15We suspected it was just something

1:13:17personal. This resulted in managers

1:13:20quitting because of misuse of the

1:13:24emergency line. So

1:13:28due to these staffing problems, we

1:13:30thought this was appropriate to deter

1:13:32misuse and abuse. If there's a true

1:13:35emergency, of course, the landlord wants

1:13:36to know about it immediately and call

1:13:38911. But this intention was to deter

1:13:41abuse of it. Now, as I mentioned before,

1:13:47the complainants asked the DCP to review

1:13:49all the rules, including the fine

1:13:51provision and this provision as well. I

1:13:54have also been in discussion with the

1:13:56DCP attorney about this provision as

1:13:58well, and I've cited authority and they

1:14:01are also reviewing. Again, if the DCP

1:14:04determines that this needs to be reduced

1:14:06or changed in any shape or form, the

1:14:08landlord will do so.

1:14:17water accumulation.

1:14:18Um, that's another common complaint in

1:14:21the complaints in the Fair Rent

1:14:23Commission complaints and also DCP

1:14:25complaints. The relevant regulation

1:14:28states that there's only a violation if

1:14:29there's standing water for 72 hours.

1:14:33That is not the case here. And in fact,

1:14:35if you look at the pictures that were

1:14:37submitted as evidence, the DCP by the

1:14:40complaintants, which I I didn't include

1:14:41in the package, but I have some with me

1:14:44if I feel the need to introduce as

1:14:46evidence, which sounds like I may, were

1:14:48really talking about large puddles.

1:14:51And these pictures were taken in July

1:14:53during that massive storm.

1:14:56They quickly dissipated. So to the

1:14:58extent there's complaints about water

1:15:01accumulation in certain areas of the

1:15:03park, we respectfully respond as

1:15:06follows. There has been severe severe

1:15:09storms in July, unusually severe and

1:15:14extended rainfall.

1:15:16So there's been a little bit more water

1:15:18accumulation than we're used to seeing,

1:15:22but the water quickly dissipates and

1:15:24there's no violations.

1:15:31In any event,

1:15:33that briefly responds to just some of

1:15:35the allegations that were made in the in

1:15:36in the in the opening statement. I

1:15:38thought it was necessary just to give

1:15:40you a preview of the rebuttal. Maybe it

1:15:42was a little bit excessive, but

1:15:57Why are we here though? We're the

1:15:59primary reason why we are here is to to

1:16:01determine if the $88 increase 16% again

1:16:06average 5% over 5 years is harsh or

1:16:09unconscionable.

1:16:11And during my presentation and you're

1:16:13going to hear from Mr. Gray and Mr.

1:16:15Mandola,

1:16:17we will show you that all the 13 factors

1:16:21that this commission should utilize

1:16:22under Connecticut General Statute 7-148C

1:16:26all weigh in favor of upholding the

1:16:29rental increase.

1:16:32Each factor clearly weighs in favor of

1:16:34upholding it.

1:16:37These factors quickly are the

1:16:40comparables. The evidence today will

1:16:42show you that all the comps that we've

1:16:45introduced are valid and that the the

1:16:47638 is at or below market rent. And the

1:16:51main comp that they rely on, the tenants

1:16:53rely on, Liberty Park or Liberty Mobile

1:16:56Home Park in Planeville is not a valid

1:16:58comp. I submitted the maps because I

1:17:01wanted the commission to clearly see

1:17:03that those lots that are significantly

1:17:05cheaper, not that much cheaper, but you

1:17:07know, meaningfully cheaper,

1:17:09they're about half half the size or

1:17:11one-third the size. You could tell on

1:17:13the map, I'll get this on my main

1:17:15presentation. There's barely a yard.

1:17:19Drive-thru Dun Mobile Home Park. There's

1:17:22a front yard, there's a backyard,

1:17:24there's a sideyard. For many of the

1:17:25lots, they have parking spaces, they

1:17:27have sheds, they have room to play in

1:17:29the backyard.

1:17:33It's like comparing a 1,000 foot to a

1:17:362,000t home in a different town. Is that

1:17:38a valid comp? We'll get to that.

1:17:42The second factor,

1:17:46the sanitary conditions.

1:17:48I've heard complaints about snow removal

1:17:50and water pressure and the like, but I

1:17:52haven't heard any complaints directly

1:17:53about sanitary conditions, but again,

1:17:56the landlord prudently maintains the

1:17:58park, has an invest has invested

1:18:00hundreds of thousands of dollars in

1:18:02capital improvements, deferred

1:18:04maintenance, and slowly making this park

1:18:05better despite losing over $350,000 in

1:18:09that over five years. That factor will

1:18:11fall in favor of upholding the rent. The

1:18:14third factor is not applicable.

1:18:18The fourth factor and fifth factors are

1:18:20also not applicable.

1:18:22The sixth factor, the repairs necessary

1:18:24to make such accommodation reasonable,

1:18:26livable to the occupants. Again,

1:18:30the landlord has invested 557,000 on

1:18:33maintenance and capital improvements

1:18:34over the past 5 years. And is that's

1:18:36while operating at a net loss. If that's

1:18:39not dedication to seeing this through

1:18:42and making this park a better place to

1:18:44live, I don't know what is.

1:18:47The seventh factor,

1:18:49I'm sorry, the eighth factor rather, is

1:18:52whether the accommodations are in

1:18:53compliance with ordinances.

1:18:55Well, there's been some complaints about

1:18:57again the snow removal, the water

1:18:58pressure.

1:19:00There's no violations or regulations

1:19:02that have been violated. None. The DCP,

1:19:06the review is still pending. And I am

1:19:08very confident, my client's very

1:19:10confident that we will get a favorable

1:19:12ruling because the evidence is very

1:19:15clear. There are no violations and the

1:19:17park is prudently maintained and in fact

1:19:19as noted before the landlord has gone

1:19:22above and beyond its duties.

1:19:26The ninth factor, the income of the

1:19:27petitioners, uh we don't know that, so

1:19:30we'll take that up as it comes.

1:19:35the 10th factor, availability of

1:19:36utilities.

1:19:38The only thing I've heard the

1:19:40complaintants mention is the water

1:19:41pressure issue. Um, but again, one was

1:19:45from a lightning strike and the others

1:19:46were for minor repairs and the water

1:19:49pressure was only out for an hour, an

1:19:51hour or two. So, the evidence will

1:19:54demonstrate that 10th factor clearly

1:19:55weighs in favor of a finding that the

1:19:58rent should be upheld.

1:20:01The 11th factor is damage done to the

1:20:03premises by the tenant. Not applicable.

1:20:0612th factor, the amount and frequency of

1:20:08increases in rental charges. Again, the

1:20:10landlord acknowledges that

1:20:13this increase was more than the previous

1:20:14ones, but it's justified. It's more than

1:20:17justified. There's a net loss of

1:20:19$350,000.

1:20:24So again that is dedication to to

1:20:27sticking this investment through and

1:20:29making it a better place.

1:20:33And the 13th factor whether the extent

1:20:35to which the income from an increase in

1:20:37rental charges has been or will be

1:20:38reinvested.

1:20:40Again they're making no money. It's all

1:20:42going back into the park. It's all going

1:20:44back into the park. The evidence will

1:20:46demonstrate that. The exhibits will

1:20:48demonstrate that.

1:20:55Before I conclude, I want to also

1:20:58mention

1:21:00maybe a semi-legal issue that needs to

1:21:02be discussed here because it has great

1:21:04impact on the park. Connecticut General

1:21:08Statute 21-85

1:21:1080 parenthesy 5 close parenthesy

1:21:13requires all rental increases of similar

1:21:16lots at mobile home parks to be the

1:21:18same.

1:21:20So whatever this commission decides, at

1:21:23least it's my interpretation as the

1:21:25parks lawyer and the way my client has

1:21:28always done this at at his parks is that

1:21:31it has to be applied to all lots. All

1:21:34lots are very similar. So for example,

1:21:38if this commission decided to reduce the

1:21:40rent, it's not just the complaints, it's

1:21:42the whole lot. And I respectfully submit

1:21:45it's going to have a devastating effect

1:21:47on the financial wherewithal of the park

1:21:49and it's not gonna be good for anyone.

1:21:51The landlord, this is really out of

1:21:54necessity. The landlord needs this rent

1:21:55increase out of necessity.

1:21:58You know, the landlord does not want to

1:22:00sell the park because if he sells the

1:22:02park, it's probably not going to be that

1:22:04good of a landlord. And interest rates

1:22:06now are very high. A new owner comes in,

1:22:08has a very high debt service, and now

1:22:10we're looking at even more expenses,

1:22:12possibly more in the red.

1:22:15He doesn't want to repurpose the land.

1:22:17He wants to keep this park as it is and

1:22:19continue to invest in it and continue to

1:22:21make it a better place. So, I only

1:22:23mentioned 20-85

1:22:25because this commission holds a lot of

1:22:27power.

1:22:29It's going to have a huge impact on the

1:22:31park.

1:22:34>> What was that subpart?

1:22:35>> Yep. Connecticut General Statute 21-80

1:22:38parenthesis 5. It's in my memo.

1:22:46So again,

1:22:48as in the complaintants opening

1:22:49presentation,

1:22:51I would urge you tonight to consider the

1:22:53big picture. The big picture. Are we

1:22:57talking about a little bit of

1:22:58landscaping here? A little bit of weed

1:23:00overgrowth? Are we talking about a

1:23:02puddle? we're talking about or are we

1:23:04talking about the future of the park and

1:23:05the financials of the park

1:23:08and my client's desire to continually

1:23:10improve the park and make it a better

1:23:12place.

1:23:14We're talking about what's a fair rent

1:23:16compared to other comps. Are we talking

1:23:19about whether this rent is justified

1:23:21based on the $350,000 my client has lost

1:23:25over the five years? That's what we're

1:23:26really talking about. So, I urge you to

1:23:28see the big picture and when you hear

1:23:31from my client and you hear from Mr.

1:23:32Amandola and you really look through the

1:23:35documents that were submitted, you will

1:23:37see that this rental increase is not

1:23:39only not harsh and unconscionable, it's

1:23:42fair, it's equitable, and it's a

1:23:44necessity. Thank you.

1:23:48>> Thank you. Um I think we're going to

1:23:51take a quick recess. Um, some of us have

1:23:53to

1:23:55um

1:23:57relieve ourselves and we'll give you

1:23:59guys five minutes. So, um, we'll take a

1:24:02recess. It's, uh, 8:39. We'll be back in

1:24:07in about 10 minutes.

1:24:10>> How are you?

1:24:12>> Back into

1:24:14at 8:50 from recess.

1:24:17All right. And so now

1:24:20we will continue with um

1:24:23>> plaintiff's case. Plaintiff's case.

1:24:26>> Complaintant's case.

1:24:28>> Yep. The complaintant's case. So we'll

1:24:30have the complaintant who whoever is

1:24:34representing the complaintant.

1:24:37Just state your name and um address for

1:24:40the record.

1:24:42Hi, my name is Jennifer Shuket. I live

1:24:45at Apple Valley Village. Um,

1:24:49I'm not going to go and repeat all the

1:24:51stuff that was talked about earlier, but

1:24:53I do want to point out that I thought

1:24:56that we're all supposed to get up here

1:24:59and give an oath of telling the truth.

1:25:02Well, our the park owner representative

1:25:04did not get up here and tell the truth.

1:25:06First of all, as I was going through the

1:25:08mounds of paperwork, which I'm sure they

1:25:11did that to not give us enough time to

1:25:13prepare questions, but just a few things

1:25:15to show credibility or lack of

1:25:17credibility on their part. They have the

1:25:19arborist report in here from Amato's

1:25:23landscaping and they have the

1:25:25gentleman's name and license number,

1:25:27Edgar Gonzalez. I just went on to the

1:25:30e-licens website and unless he is a

1:25:33barber,

1:25:35a home improvement contractor, an

1:25:37emergency medical technician or a youth

1:25:40camp director, he's not licensed to be

1:25:43an arborist in the state of Connecticut.

1:25:45So, this is a lie.

1:25:47Um,

1:25:50also they have this landscaping company

1:25:52on our property without any registered

1:25:54vehicles. I highly doubt that they're

1:25:57insured as well, but we are required to

1:25:59carry Pyramid on our policies. I don't

1:26:01see the fairness in that. Um, I'm also

1:26:04seeing several invoices in those

1:26:06gigantic piles of invoices from Pyramid

1:26:09to Pyramid.

1:26:11So, I'm sure what they're saying they're

1:26:14dumping into the park is probably not

1:26:18factual as well. But I would like to

1:26:20know what improvements have been made

1:26:22because if you have driven around the

1:26:24park, it it does no improvements have

1:26:27been made. I was told by residents who

1:26:29have been here since Pyramid owned it

1:26:31that they had a barbecue and they told

1:26:34everybody, "We're going to put a

1:26:35clubhouse in. We're going to put a pool

1:26:37in. We're going to put all this stuff

1:26:38in." And they've never done it. They've

1:26:41never done any improvements. The

1:26:43so-called recycling dumpster just on

1:26:46Thursday has now a sticker on it that

1:26:48says cardboard only. That's not really

1:26:51recycling and there's no instruction. I

1:26:53mean, now we can clearly see it's

1:26:54cardboard only, which is fine. Now, we

1:26:56all know and we can all follow those

1:26:57instructions, but I'd ask residents who

1:27:00have been here for 20 years and they're

1:27:01like, "No, it's recycling. What do you

1:27:03put in recycling?" There's different

1:27:05things that can and can't go in it. So,

1:27:07how are the residents supposed to know

1:27:09what belongs in a dumpster without clear

1:27:11instruction of it? They are lacking.

1:27:14They don't they don't come to the park

1:27:16every week. Just recently, in the past

1:27:18month, do we see our property manager

1:27:20come one day and she walks around the

1:27:22park there for maybe 45 minutes and she

1:27:25leaves. I'm seeing invoices in there

1:27:27from the landscaping company that they

1:27:29come here. They're charging $2,200 a

1:27:32month and they come and they sit in

1:27:34their truck for two hours when they show

1:27:35up in the morning. They mow for an hour

1:27:37and a half and then they sit in their

1:27:38truck for three hours and then they

1:27:39leave. This is not responsible

1:27:42management of a property. They do not

1:27:45care about the property. They have not

1:27:46shown it. It's very infuriating. I would

1:27:50love to have a park that I'm proud of. I

1:27:52don't want to have people over because

1:27:54it looks horrible. It is not maintained.

1:27:57It is not worth the increase that

1:27:59they're giving us. and the losses. I I

1:28:01don't even know where the losses are

1:28:02going because I don't see it. Um I also

1:28:07to show credibility see an invoice in

1:28:10there for a camera.

1:28:13There's no camera on the property. One

1:28:16of our residents put up a solar light by

1:28:18the dumpster so you can see when you go

1:28:20and throw stuff away after dark. They've

1:28:23never put a camera up, but yet they're

1:28:24billing for a camera. So, I just wanted

1:28:27to say that I I don't I don't believe

1:28:30half of the stuff that's in that pile

1:28:32and I don't believe that they are being

1:28:34fair and honest and truthful about

1:28:37anything that they're going to say here

1:28:38tonight. Um, leading next, I would like

1:28:42to can I call up a witness because we

1:28:44have someone that has helped us out

1:28:47tremendously.

1:28:48>> So, you're providing ma'am through the

1:28:50chair. You're providing testimony so

1:28:52council has the opportunity to

1:28:53cross-examine you before Okay.

1:28:55>> Anybody else is going to testify. So, if

1:28:58you have nothing else to testify to,

1:29:01Attorney Shankle, you please feel free

1:29:03to inquire.

1:29:04>> Do I stay here or do I go back down

1:29:06there?

1:29:06>> So, it's kind of awkward. I would say

1:29:10>> Yeah,

1:29:12>> you can stand over here. Attorney.

1:29:15>> Oh, me stand. Okay. Yes.

1:29:16>> Sorry. We'll make

1:29:18>> No problem.

1:29:19>> Everyone can hear.

1:29:20>> Yeah.

1:29:21>> Attorney Shankle.

1:29:22>> Just one second.

1:29:23>> Sure.

1:29:32While he's coming, I just want to um

1:29:34when you come up, you're going to give

1:29:36all your testimony about why you know

1:29:40everything. Present all your evidence.

1:29:42Okay.

1:29:43>> Even though it's been said previously.

1:29:44>> Yes.

1:29:45>> Okay.

1:29:45>> Just Well, that was just an opening

1:29:48statement was our understanding.

1:29:50>> Gotcha. But that has a lot of test. You

1:29:53know, our complaints are in that. It's

1:29:55It's a lot. That's why we prepared it

1:29:57the way we did. We didn't think you guys

1:29:59would want to be here until midnight.

1:30:01>> Well, we That's to give us a chance to

1:30:02review it ahead of time.

1:30:05>> You still present your evidence?

1:30:07>> Okay.

1:30:20>> Should we have more people come up and

1:30:22>> No.

1:30:22>> No. No. Okay,

1:30:23>> ma'am. There's I'm sorry, but this is

1:30:25for us to decide on this, so please

1:30:27don't offer any uh options for us. Thank

1:30:30you,

1:30:32>> Attorney Shankle, if you if you wouldn't

1:30:34mind.

1:30:35>> Thank you.

1:30:38>> I have no question.

1:30:40>> Thank you.

1:30:42>> Um

1:30:42>> present your next witness.

1:30:44>> I can present a witness. Yeah.

1:30:45>> Okay.

1:30:46>> So, I would like to call up

1:30:48>> um Rebecca. She has been involved with

1:30:53concerns at Apple Valley since the

1:30:54beginning of all of the very first

1:30:57complaint that was submitted back in

1:30:59June before the storm. And she has

1:31:02significant communication with both

1:31:04residents and Pyramid Reality.

1:31:15>> Hello, I'm State Representative Rebecca

1:31:17Martinez. My address is 8 Irving Street,

1:31:20Planeville.

1:31:23I think it's most important place to

1:31:26start is what these residents are

1:31:29actually renting

1:31:31and to really clarify that that they own

1:31:34their homes. So if their roof leaks,

1:31:35they fix it. If their furnace goes, they

1:31:37replace it. If their plumbing breaks,

1:31:39they pay the plumber.

1:31:41They insure the home, maintain it, and

1:31:43pay property taxes on it. They also mow

1:31:46their lawns, maintain their landscaping,

1:31:49and keep their lats clean. What they are

1:31:52primarily paying Pyramid for is the land

1:31:54underneath that home and the services

1:31:56and infrastructure that come with that

1:31:58land. Pyramid's own March 18th, 2026

1:32:02rules say sewer, water, service, and

1:32:05trash pickup are managed by the owner.

1:32:08Those same rules specifically say the

1:32:10park is responsible for maintaining and

1:32:11pruning of large trees and large shrubs.

1:32:14Connecticut law also places

1:32:16responsibilities on the park owner

1:32:18involving drainage, common areas, park

1:32:20roads, garbage removal, and park

1:32:22provided water and sewer infrastructure.

1:32:25This is sorry, this distinction runs

1:32:28through everything that I have seen at

1:32:30Apple Valley.

1:32:31My involvement actually began shortly

1:32:34before the July 4th storm when a

1:32:35resident contacted me about a fair rent

1:32:37complaint. I was beginning to hear

1:32:39concerns about the rent and about the

1:32:41conditions at the park. But July 4th is

1:32:44when my involvement became much deeper.

1:32:47One of the things that has stayed with

1:32:49me from that day on July 7th, 3 days

1:32:52after the storm, is I got there before

1:32:54the property owners did. I am the state

1:32:57representative. I do not own Apple

1:32:59Valley. I am not responsible for those

1:33:01trees. Those roads, that infrastructure

1:33:03or making sure residents can safely get

1:33:05in and out. When I arrived, trees were

1:33:08down and leaning. There were electrical

1:33:10wires on the ground. Access in and out

1:33:13of the park was disrupted. A tree had

1:33:15come directly down onto a resident's

1:33:17home and vehicle. And that home was

1:33:20later posted as unsafe.

1:33:22And this was not a July 4th storm

1:33:25followed by by a July 5th cleanup.

1:33:28This storm happened July 4th. Cleanup

1:33:30didn't even begin until July 9th, 5 days

1:33:33later.

1:33:35There are seniors in this community.

1:33:37There are residents with serious medical

1:33:39needs. One resident relies on oxygen and

1:33:42had to be transported from Apple Valley

1:33:44by ambulance twice. residents told me

1:33:46and showed me video that because of the

1:33:50access situation, the ambulance had to

1:33:52come through the neighboring elementary

1:33:54school property to reach that resident

1:33:56and getting the resident out and into

1:33:58the ambulance became a lengthy process.

1:34:01I have heard similar concerns during the

1:34:03winter storms. Healthcare workers live

1:34:04in this park and they've told me about

1:34:07being unable to get out to work or

1:34:09finishing a shift and being able to get

1:34:10back into their own community because

1:34:12the road has not been cleared in a

1:34:14reasonable amount of time. After July

1:34:174th, whenever another significant storm

1:34:20came through, I started hearing from

1:34:22residents again, emails, calls, people

1:34:24looking at trees around their homes and

1:34:26wondering what was going to come down

1:34:28next. And when I tell you the fear was

1:34:32real. When I first came into that park,

1:34:35I had several residents look me look at

1:34:38me right in the face and tell me that

1:34:40they hadn't called the emergency line

1:34:43yet because they were afraid of a $350

1:34:46fine. And they didn't even know how they

1:34:48were going to replace the food in their

1:34:50fridge and that loss, let alone a $350

1:34:53fine. I said, "No problem. I'll call

1:34:55that emergency line, that 24 access

1:34:57line. I called and it was an answering

1:34:58machine. I did not reach anybody and

1:35:01nobody got back in touch with me until

1:35:03the next day.

1:35:06On July 27th, another storm coincided

1:35:10with a water outage and generator

1:35:12concerns. On August 7th, another storm

1:35:15and an additional tree came down. That

1:35:18is when I started asking what

1:35:20preventative tree maintenance had been

1:35:21done. I spoke directly with the property

1:35:24manager, Mary, at Pyramid. Mary told me

1:35:27that arborist inspects the trees at

1:35:28Apple Valley every year. And I remember

1:35:31thinking,"Great, that's so reassuring

1:35:33because these people are really scared."

1:35:35I said, "Great. Can you just show the

1:35:37report?" I told her that residents would

1:35:38feel so much better if they could just

1:35:39see that these trees were being

1:35:41professionally inspected every year.

1:35:43What was inspected, what the arborist

1:35:44found, and what work was recommended,

1:35:46and what was completed. Then Mary

1:35:48emailed me back and said, "There are no

1:35:50reports." Then I learned about the

1:35:52emermergency line that I spoke of. Um,

1:35:56now think about what this does to a

1:35:57resident. Your water goes out. You have

1:35:59an electrical concern. A tree has

1:36:02fallen. Before you even call the number,

1:36:03you're trying to figure out whether you

1:36:05can afford whether or not to pay a fee

1:36:08that can come at you.

1:36:14Um,

1:36:16Connecticut's regulation is very clear.

1:36:18A mobile home park has to have a system

1:36:20that allows residents to contact a

1:36:22manager, attendant, or caretaker at any

1:36:24time. The regulation specifically says

1:36:26that answering the answering machine by

1:36:28itself does not comply with that

1:36:30requirement. When I called the number

1:36:32residents were given, an answering

1:36:33machine was exactly what I reached.

1:36:36I have been back to Apple Valley

1:36:38repeatedly since July 4th. I represent

1:36:40multiple manufact manufactured home

1:36:42communities, so I do have other

1:36:44communities to compare it to. And of the

1:36:46manufactured home communities I

1:36:48regularly see in my district, Apple

1:36:49Valley is the most visually uncmp. I

1:36:53have personally seen the potholes. I

1:36:54have stood next to the standing water.

1:36:56I've seen the weeds and the overgrowth

1:36:57in the park controlled areas in the

1:36:59taller grass and significant insect

1:37:02activity. And on multiple visits, I have

1:37:04seen the dumpster heaping over. What

1:37:07makes the contrast especially noticeable

1:37:09is how strictly residents themselves are

1:37:11held to rules. On March 11th, residents

1:37:14received a lot maintenance notice

1:37:15telling them that management would not

1:37:17send additional warnings and that fines

1:37:19would be automatic and continue until

1:37:22residents emailed verifiable

1:37:24photographic proof that cleanup had been

1:37:26completed. But it didn't even state what

1:37:28that cleanup consisted of. So imagine

1:37:31being so afraid that you're going to get

1:37:32hit with a daily fine of $25. That's 175

1:37:36a week or $750 in a 30-day month. If a

1:37:40resident can't accumulate hundreds of

1:37:42dollars and penalties over the condition

1:37:44of a yard, that resident should know

1:37:46exactly what is wrong, exactly what has

1:37:48to be corrected, and exactly where the

1:37:49resident's responsibility ends and that

1:37:51managements begin. And that's where I

1:37:54disagree with uh the council for the

1:37:56park owner about the fees being

1:37:59important and imperative to this case

1:38:00and whether they're a DCP concern or

1:38:02fair rent concern. Not only is it a

1:38:05financial concern, but most of the fees

1:38:08that you'll see in the the binder,

1:38:10they're not even disclosed on a lease.

1:38:11Therefore, they're they're not legal.

1:38:14Then there are services residents are

1:38:16now being asked to pay more for trash.

1:38:18Pyramid's own rules say trash pickup is

1:38:20managed by the owner. Residents are now

1:38:22being asked to pay a separate monthly

1:38:23trash fee. Yet, I've personally seen the

1:38:26dumpster overflowing. If every household

1:38:28is going to pay separately for that

1:38:30service, the record should show exactly

1:38:32what service they are receiving, how

1:38:34much capacity is being provided, and how

1:38:36often it's being picked up. Then the

1:38:38water. On September 6, 2023, following

1:38:41an on-site inspection conducted on July

1:38:4327th, 2023, the Connecticut Department

1:38:45of Public Health drinking water section

1:38:47issued its sanitary survey report for

1:38:49Apple Valley Village. That report says

1:38:52Apple Valley is served by a single

1:38:54drilled well. DPH strongly recommended

1:38:56either installing a second well or

1:38:58interconnecting with another approved

1:39:00public water system. DPH also

1:39:03specifically said it continue to

1:39:04recommend connecting Apple Valley to

1:39:06Southernington Water Department line

1:39:08that fronts the property. That was in

1:39:1023. Then look at 2026. January 5th,

1:39:14extreme low water pressure email was

1:39:16sent out. January 6, management reports

1:39:18a broken underground water pipe and a

1:39:20shutdown for repairs. February 4th,

1:39:22another low pressure event. March 18th,

1:39:24notice of another planned shutdown for

1:39:26work involving underground water tanks.

1:39:28March 20th, another shutdown for

1:39:29underground water line repair. July

1:39:3127th, residents lose water during a

1:39:33storm and management later says a well

1:39:36pump contractor and electrician are

1:39:38being sent. All of these notices were uh

1:39:41shared with me.

1:39:45Pyramid's own documents say the sewer

1:39:47service is managed by the owner.

1:39:48Residents are now being asked to pay a

1:39:50separately monthly charge for sewer

1:39:52charge per home. I do not have Pyramid's

1:39:55water system expenses. I do not have

1:39:56Pyramid sewer bills. I do not have the

1:39:59trash contract, but Pyramid does. So, if

1:40:01increased expenses are being used to

1:40:03justify increased charges, the invoice

1:40:05contracts and actual operating expenses

1:40:08should show it. Then look at the rent

1:40:10itself. It went up 3% for years as

1:40:13stated in the opening statement. Those

1:40:17were relatively modest increases. Then

1:40:19it jumped to 550, nearly 8% last year.

1:40:22Now residents are being asked to pay 600

1:40:24in base plus $12 for water, 1417 for

1:40:27sewer, and 12 for trash. That brings the

1:40:29common monthly obligation to 63817. That

1:40:32is another 8817 every month. Roughly a

1:40:3516% increase. And when I look at the

1:40:38history, one of the biggest questions I

1:40:40have is what's changed for the

1:40:42residents? What's got better? What's

1:40:44gotten repaired? What was improved? what

1:40:46was reinvested because I have been

1:40:48through this park repeatedly. I still

1:40:51see some potholes. There's standing

1:40:52water. I've seen the dumpster

1:40:53overflowing. Residents are still raising

1:40:55concern about the trees, water, snow

1:40:57removal, emergency response, and common

1:40:59area conditions. So, where's the

1:41:01corresponding reinvestment? What was

1:41:03repaired? What was replaced? What

1:41:05improved for the people paying more?

1:41:09People have been so afraid to complain,

1:41:12afraid to put their names on things,

1:41:14afraid to question management. Some were

1:41:15afraid to call me and insisted that when

1:41:19I returned their call, I wouldn't share

1:41:21their names. And that is why I'm proud

1:41:24of the residents who stepped forward

1:41:25tonight. For some of them, sitting here

1:41:27and putting their names behind these

1:41:29concerns took a lot of courage. And I

1:41:32think the written communications help

1:41:33explain why. residents received a formal

1:41:35notice from Pyramid stating, "Please be

1:41:37advised that your lot rent still

1:41:40increased. However, you are on a

1:41:41month-to-month schedule and lost any

1:41:44protections that were included in your

1:41:46lease." When I saw that language, I

1:41:48immediately questioned Mary about it.

1:41:51These are not people deciding whether to

1:41:53renew an apartment. They own a home

1:41:55sitting on this land. Then on August for

1:41:5717th, Mary emailed me and wrote that

1:42:00those who had filed fair rent cases were

1:42:02excluded from having to return leases

1:42:04until after the fair rent cases had been

1:42:06heard. At that point, the fair rent

1:42:08hearing had already been moved to

1:42:10October. So residents challenging the

1:42:13rent were were being told originally

1:42:17that they could lose that they can lose

1:42:20their rights. No one at the park Oh,

1:42:23sorry. Then uh to verify the next day,

1:42:24August 18th, Mary emailed me again and

1:42:26wrote, "No one in the park has been put

1:42:27on month-to-month lease. Letters went

1:42:29out today saying the communication went

1:42:31out in error."

1:42:35You do not know a formal letter is an

1:42:37error when you open it. You only know

1:42:38that the company controlling the land

1:42:40underneath your home has sent you a

1:42:42letter telling you that you have lost

1:42:43your protection. And that creates

1:42:45confusion and it creates fear. Imagine

1:42:48somebody saying that if you don't return

1:42:50your lease and your documents by a

1:42:52certain date, your your protections are

1:42:54gone in your monthto monthth and it

1:42:55could cost you 10 to $20,000 to move

1:42:58your home. And there's another piece of

1:43:00the written rules. Did I I'm sorry, lost

1:43:04my spot here. Then add the June 1st

1:43:08renewal notice threatening $25 per day

1:43:10charges over the lease, rules and

1:43:11insurance paperwork, the $350 emergency

1:43:14call policy, the conflicting

1:43:15month-to-month notices, and the broad

1:43:17entry language. Each document can be

1:43:19examined separately. Residents live with

1:43:21all of them together, and they cannot

1:43:23simply say final move. These are called

1:43:25mobile homes, but they are not they are

1:43:27not mobile, costing over $20,000 to move

1:43:30them. Their savings are tied up in these

1:43:31homes. Their homes belong to them.

1:43:33somebody else controls the ground

1:43:35underneath it and that makes every fee,

1:43:37every notice, every statement about

1:43:38losing protections carry greater weight.

1:43:41I am careful about assigning anybody's

1:43:43motive, but I can speak to the effect

1:43:45that I've personally seen residents who

1:43:47are genuinely afraid to speak up in a

1:43:49community where they own their homes.

1:43:51Residents have also brought these

1:43:52concerns directly to the Department of

1:43:54Consumer Protection and a full

1:43:55investigation is underway.

1:43:58And that brings me back to value.

1:44:00Liberty Liberty Park in Planeville is a

1:44:02meaningful comparison because the

1:44:04amenities are much closer to Apple

1:44:05Valley. There's no pool. There's no

1:44:07community room. The comparable

1:44:09information in the hearing materials

1:44:11list Liberty as at 475 a month and

1:44:14identifies public water, public sewer,

1:44:16trash, recycling, road maintenance, and

1:44:18property management among the included

1:44:20services. I also know that the comm I

1:44:23also know that community firsthand and

1:44:24when I drive through it, the pavement is

1:44:26maintained. I do not see the same

1:44:27potholes. I do not see the same standing

1:44:29water problems. I do not see the weeds

1:44:31taking over common areas.

1:44:34The property looks maintained. When I

1:44:36put this whole picture together, there's

1:44:37a clear disconnect between what those

1:44:39homeowners are responsible for, what

1:44:40they are being charged, and what they

1:44:42are receiving in return. They own the

1:44:44home, they repair it, they insure it,

1:44:45and they pay taxes on it. What they are

1:44:47paying pyramid for is the land and the

1:44:49services that come with that land. So,

1:44:51look at the full, please look at the

1:44:53full picture. the roads, the trees, and

1:44:54the lack of inspection reports, the

1:44:56standing water, the overflowing

1:44:57dumpster, the repeated water problems,

1:44:58the emergency response, the notices and

1:45:01escalating fines, the conflicting

1:45:02communications about leases and

1:45:04protections, the right to privacy inside

1:45:06homes the residents themselves own, and

1:45:09the question of what actually has been

1:45:10reinvested back into the property. The

1:45:12question is not simply whether 63817 is

1:45:15a large increase from 550. The question

1:45:17is whether what these residents are

1:45:19being charged reflects the actual value

1:45:21that they are receiving. they are

1:45:23homeowners, their homes are their

1:45:25investment and their security. And those

1:45:26are the facts I believe are important

1:45:28for the commission to consider. And I do

1:45:31just want to um draw attention to a

1:45:35couple other things that um I heard this

1:45:37evening.

1:45:42>> She heard

1:45:44>> noted

1:45:46what?

1:45:48>> Okay.

1:45:48>> Go ahead.

1:45:49>> Okay. Um, so it was brought up earlier

1:45:55um about how the park owner was acting

1:46:00in the best interest and went above and

1:46:02beyond for the resident that had the

1:46:05trees fall on fall on her home. That

1:46:08resident his name was Janet Jud and

1:46:11that's how I first heard about Apple

1:46:13Valley. It was before the storm. It was

1:46:15she came to me for advice on the fair

1:46:17rent process.

1:46:19um June 23rd, 2026,

1:46:22she contacted me in my office about a

1:46:25second consecutive $50 per month rent

1:46:28increase and um her concerns about the

1:46:31charges and I spoke with her and I

1:46:33connected her with uh Dave Delorei who

1:46:36uh in statute is an advocate for

1:46:39residents living in mobile home

1:46:41communities. Um, I spoke directly with

1:46:44Janet on June 30th and discussed the

1:46:47rent increase and the park upkeep

1:46:49conditions. On July 1st, I followed up

1:46:52and discussed gathering information

1:46:54about conditions. And she stated she was

1:46:56worried about the trees. On July 4th,

1:47:00major storm tree came down on Janet's

1:47:02home and vehicle, leaving the home

1:47:03unsafe to occupy and causing major

1:47:05displacement issues. July 5th, Janet

1:47:09reported the utility shut off. She

1:47:11reported that the water and electricity

1:47:12had been disconnected and both are

1:47:13disconnected from outside of the home

1:47:16with the shut offs located outside.

1:47:19July 6th, the town uh posted unsafe

1:47:22structure notice um danger unsafe

1:47:25structure notice on lot 25 prohibiting

1:47:27occupancy until the property was made

1:47:29safe. July 13th, I began broader

1:47:32assistance efforts. Meanwhile, the tree

1:47:34was still on her home July 13th and the

1:47:36storm was July 4th. I outreach was made

1:47:39involving Connecticut Insurance

1:47:41Department, Southernington Officials,

1:47:42Human Services, the Red Cross concerning

1:47:44Janet's insurance claim, displacement,

1:47:45relocation help. July 15th,

1:47:49um part of the tree was removed from the

1:47:52home

1:47:53>> and we don't have a complaint.

1:47:56>> Janet received

1:47:58a letter from from the park owner's

1:48:02attorney um directing her to remove the

1:48:04damage manufactured home. Directing her

1:48:07to remove the damage manufactured home

1:48:08by July 21st, saying she had a few days

1:48:11to get this home out of there.

1:48:12>> Miss Martinez, I just have a question

1:48:14through the chair. Um, yes,

1:48:15>> Miss Jud is not uh a complainant in

1:48:18these cases, is she?

1:48:20>> She is not a complaintant to these

1:48:21cases, but I do believe I wanted to resp

1:48:25that was the only question that I had. I

1:48:26just wanted to confront her. She's not a

1:48:27complaint in here today.

1:48:29>> Okay. No, she's she's not um

1:48:31>> strike anything with this.

1:48:34I'm speaking to Miss Dood because she

1:48:36was brought up over here and about how

1:48:41the park owner really went above and

1:48:43beyond uh for her and this situation.

1:48:46So, I'd like to just speak on what I

1:48:49know about that.

1:48:49>> That was not part of evidence. That was

1:48:51just his opening statement, but that's

1:48:53fine.

1:48:54>> Okay. Um Janet on uh July 16th, Janet

1:48:58reported um park representatives came

1:49:02without notice. There was a drilled lock

1:49:03placed on a lock box in the home and

1:49:05entered

1:49:05>> cross examiner.

1:49:07>> Um July 17th,

1:49:10Dave Delorey

1:49:12reported, and I'm sure he'll speak as

1:49:14well, received to a no trespass order

1:49:17barring him from Apple Valley Village.

1:49:20Janet had also reported that there was

1:49:22an offer to pay for the removal of her

1:49:25manufactured home if she did not

1:49:27continue pursuing the fair rent

1:49:29complaint.

1:49:31July 21st deadline uh with the deadline

1:49:36hit for the attorney's letter to for the

1:49:38removal of Janet's home. July 22nd

1:49:41should have been Janet's fair rent

1:49:43hearing. It was on the agenda and it was

1:49:45scheduled to happen. When I called Janet

1:49:48to see how it how she made out in

1:49:50negotiation, she told me that her

1:49:52attorney adviser she could no longer

1:49:54speak about this issue.

1:49:56So that's um what I had known about that

1:49:59case and what happened and it wasn't

1:50:02ever brought to me that uh she was

1:50:04feeling anybody went above and beyond.

1:50:07And I know that the council's attorney

1:50:10also brought up the Brford case and they

1:50:13would know about that Brford case really

1:50:14well because they own that park too and

1:50:17that was the same attorney. I uh do

1:50:21disagree though with um what they

1:50:24reported as the

1:50:27findings for that Brford case and

1:50:32I'll be able to find it for you. Trees

1:50:35were an issue there too.

1:50:40>> Well, he's going to get to cross.

1:50:43Um so they had said that they had won

1:50:46and it was very similar to this case but

1:50:49the basic rent increase of 8.5% was

1:50:52approved utility charge for water and

1:50:53sewer were disallowed. They did not

1:50:55allow those fees. Um in some lot rent is

1:51:00set to 633 per month plus $11 fee per

1:51:03month for um trash rent charge of 644.

1:51:07So, they did not get all of their fees

1:51:09put in. Um,

1:51:13however,

1:51:16and they did set into precedence um what

1:51:18the park owner's attorney was talking

1:51:20about about the same rent um having to

1:51:23happen for every um home. That's not the

1:51:27way the the statute reads, but they did

1:51:30make that precedent. So, I think that

1:51:32was great in that case that um everybody

1:51:34was able to go for that. What what the

1:51:36law actually states is um as I'm

1:51:40familiar with it for writing mobile home

1:51:42legislation and meeting

1:51:44>> is that representative you're you're

1:51:45just providing testimony with regard to

1:51:47what's going on at the park, not

1:51:49something else that happened in another

1:51:50case. So, I'm going to ask you if you

1:51:53have anything else relevant to these

1:51:54proceedings, if you could please do

1:51:57that. Uh, we still have plenty of people

1:51:59that would like to be heard. Um, and

1:52:01council still has the right to

1:52:02cross-examine your testimony.

1:52:04>> Absolutely.

1:52:05>> Thank you.

1:52:05>> No problem. I'm That's fine. I'm all

1:52:07set.

1:52:08>> Thank you. Um, council has the right

1:52:11>> we'll have you step you can step you can

1:52:13step to this microphone.

1:52:15>> We got a mic here or you can even take

1:52:17that one

1:52:22>> and you could you could

1:52:28One second.

1:52:39>> Can you hear me? Okay.

1:52:40>> No. No.

1:52:42>> Testing. Testing.

1:52:43>> Yeah. You got to stay right on it. You

1:52:45want to sit on the other side. There you

1:52:46go.

1:52:49>> Stand on the other side. Can that get

1:52:52moved to

1:52:54>> off the dis?

1:52:57>> Okay.

1:52:59>> Testing. Testing.

1:53:00>> Yep.

1:53:06>> Thank you,

1:53:10>> representative. You offered testimony.

1:53:12>> That close to you, unfortunately. Thank

1:53:14you. And just speak right into it. You

1:53:16offered testimony

1:53:18that the landlord did not respond until

1:53:223 days after the July storm. Is that

1:53:24correct?

1:53:25>> No. I provided testimony that I

1:53:27responded 3 days after uh the storm. Um

1:53:30the testimony I provided stated that no

1:53:32cleanup efforts began until 5 days after

1:53:36the storm, July 9th.

1:53:37>> Okay. Were you aware that landlord

1:53:40attempted to start cleanup efforts

1:53:41immediately? Were you aware of that

1:53:43fact? I'm aware that um the property

1:53:46manager stated there was a tree um

1:53:48blocking the road. I'm telling you, I

1:53:51was standing on the property and was

1:53:52able to get through. The tree was

1:53:53cleaned up 3 days after as I was in the

1:53:55park seeing everything firsthand. I'm

1:53:57also aware that there were food

1:53:58deliveries, Amazon deliveries, um other

1:54:01deliveries and unfortunately an

1:54:02ambulance that had to come in.

1:54:05>> Are you aware that Ever Source told the

1:54:07landlord that they could not start

1:54:09cleanup efforts immediately because of

1:54:10downed power lines? Are you aware of

1:54:12that specific fact?

1:54:15>> I spoke to the property manager and

1:54:17asked specifically why cleanup efforts

1:54:19had not taken place and they said it was

1:54:21a large storm. Um, but I can tell you

1:54:24that the residents had reported having

1:54:26to move the tree out of the way that

1:54:29blocked the entrance. So, um, no, I'm

1:54:32I'm not aware that Eversource had ever

1:54:34stated that. And when I asked the, uh,

1:54:37property manager, I didn't get that

1:54:38response then either.

1:54:40>> Okay.

1:54:43So, if Eversource did not allow the

1:54:45landlord to start immediately, is it

1:54:48reasonable that the landlord starts as

1:54:51soon as Eversource says it's safe for

1:54:53the arborist to start? Is that

1:54:54reasonable start date?

1:54:56>> According to the paperwork that um you

1:54:58provided that I was able to look at just

1:55:00this evening, it doesn't look like the

1:55:02arborist was in there until August. But

1:55:04as far as the cleanup efforts and um

1:55:08Eversource,

1:55:09I have not heard anything that

1:55:10Eversource restricted uh especially the

1:55:14entrance to the park for 5 days.

1:55:54I'm going to refer to exhibit E.

1:55:57Arburish report is part of exhibit E.

1:56:03>> Attorney Shankle, are you offering

1:56:04exhibit E as a full exhibit?

1:56:06>> Yes.

1:56:07>> Okay. We're going to uh motion to

1:56:09approve Motion to approve exhibit E as a

1:56:12full exhibit.

1:56:14>> Okay. I'm going to give you the arborist

1:56:16report and I want you to look at

1:56:20paragraph 4.

1:56:21>> Hold on one second. I I I've got a

1:56:23motion pending.

1:56:23>> Oh, sure.

1:56:25>> Thank you.

1:56:27All in favor?

1:56:28>> I

1:56:29>> I.

1:56:30>> Motion passes.

1:56:34>> May I proceed?

1:56:34>> This is exhibit E.

1:56:35>> Yes, please.

1:56:38>> Isn't it true that the Arbor report

1:56:40states that the Arborous team started

1:56:43work in July and worked for two and a

1:56:45half weeks?

1:56:49>> Paragraph four.

1:56:51>> Yes, in July 2026 without a date.

1:56:54>> Thank you.

1:56:55Correct.

1:56:57>> What page of that?

1:56:59>> Um, the arborist report. Okay. So,

1:57:01there's a few things in exhibit E.

1:57:02>> Page three.

1:57:04>> Uh, it's actually

1:57:06she has it. I I don't have it in front

1:57:07of me. I think it's page one of the ar

1:57:09>> page one. The arburous report. Thank

1:57:12you.

1:57:12>> There's a few things for exhibit E. The

1:57:16first packet is a letter to Cynthia

1:57:18Fernandez who is an attorney at DCP. The

1:57:22second packet is the arborist report

1:57:24signed by a licensed arborist,

1:57:26>> Mr. Ed Gonzalez.

1:57:27>> Yes.

1:57:30>> And that's what I'm referring to. It's

1:57:31the fourth paragraph on page one.

1:57:49>> You could take Yeah, please repeat the

1:57:50arbit. I'm sorry.

1:57:52>> Take you can review the arburish report

1:57:53because I may have I think I have one

1:57:55more question.

1:57:55>> Go for it.

1:58:00>> Isn't it true that the licensed arborist

1:58:03certifies that the park is safe and that

1:58:07all of the trees were trimmed as

1:58:09necessary?

1:58:10Isn't that true?

1:58:16Darbor stated, "I have already inspected

1:58:18these trees shown in the pictures and

1:58:19that in my opinion, they are safe and

1:58:21none of them need to be taken down or

1:58:24trimmed. I will continue to monitor

1:58:26these trees." And I'm sorry, I just want

1:58:27to make sure I'm answering you

1:58:29correctly. Was I supposed to also find

1:58:31in here where it said that Everest

1:58:33didn't let them start till a certain

1:58:34day? Oh, okay.

1:58:36>> Thanks.

1:58:36>> So, it does say that, correct?

1:58:37>> It said exactly what I just read back to

1:58:39you. Correct.

1:58:39>> And just for way background, are are are

1:58:41you a licensed arborist?

1:58:42>> I am definitely not. I am a nurse and a

1:58:45state representative.

1:58:46>> And did you ever go out to the property,

1:58:48the mobile home park with a with your

1:58:50own licensed arborist?

1:58:52>> I did not cuz that's not my

1:58:53responsibilities. It's the park owners.

1:58:55>> Yes or no question. And he did. It's in

1:58:57the papers.

1:58:58>> Okay.

1:59:01You testified that you had called the

1:59:04emergency line. Is that correct?

1:59:06>> Correct.

1:59:06>> Okay. Are you a resident at the park?

1:59:09>> I am not.

1:59:10>> Okay.

1:59:11Are you aware that emergency line is for

1:59:13the residents?

1:59:14>> I call I called the emergency line on

1:59:17behalf of residents that were too afraid

1:59:19that they wouldn't be able to afford a

1:59:21$350 charge and I stated that in my

1:59:23message.

1:59:24>> Okay. And did you were you able to state

1:59:27that you were a resident because you're

1:59:29not?

1:59:29>> I did not state that I was a resident. I

1:59:31stated that I was state representative

1:59:32Rebecca Martinez calling on behalf of uh

1:59:35residents at Dunham Mobile Park.

1:59:45You had mentioned that you observed a

1:59:47dumpster overflowing. Is that accurate?

1:59:49>> Correct.

1:59:50>> Okay. Did you look inside the dumpster?

1:59:52>> I did not.

1:59:53>> Okay. So, you wouldn't have known then,

1:59:55for example, there could be big boxes

1:59:57that were not broken down or furniture.

1:59:59>> I have no idea what was in the dumpster.

2:00:01All I can uh talk about is the the

2:00:04distinct uh odor from quite a distance

2:00:07and that it was uh heaping over.

2:00:09>> Okay. You also testified that you

2:00:12observed water at the park. Is that

2:00:14correct?

2:00:15>> I Yes. I um I observed uh standing water

2:00:19in some driveways. I was there um during

2:00:23rain spout that I saw afterwards and uh

2:00:26did see the standing water. Correct.

2:00:27>> That was after the storms, correct?

2:00:30It was I've been in there a dozen a

2:00:34dozen to 18 times since then. Um yes,

2:00:36not only the July 4th storm, but yes,

2:00:39there's standing water that the the

2:00:41residents let me know obviously turns to

2:00:43ice during the winter and uh they were

2:00:45very concerned about that.

2:00:49>> So in other words, the the water that

2:00:50puddles in the driveway that did you

2:00:52observe the ice?

2:00:52>> I did not observe the ice. I observed

2:00:54the puddles of water and the concern

2:00:56behind it was the standing waters. But

2:00:58in the winter when that water turns to

2:00:59ice that it's a safety hazard.

2:01:02>> Okay. Did you observe standing water for

2:01:0672 hours?

2:01:08>> I cannot say that I observed it for 72

2:01:11hours. I can say that I observed it on

2:01:14uh multiple occasions, but I didn't set

2:01:16a timer afterwards.

2:01:18>> Okay. So you you you cannot say with

2:01:19certainty that water was there for 72

2:01:21hours straight. Is that correct? I

2:01:22cannot. Okay.

2:01:29You mentioned that

2:01:32you've se observed potholes and other

2:01:35issues that are not present at other

2:01:36parks. Is that correct?

2:01:38>> I talked about one park in particular

2:01:40that visually um appears to be kept up

2:01:46significantly especially the pavement is

2:01:49in um significantly better shape.

2:01:51>> What park is that?

2:01:52>> Liberty and Planeville.

2:01:54>> Okay.

2:01:55Are you aware that the lots at Liberty

2:01:57are significantly smaller compared with

2:01:59the ones at Dunham?

2:02:02>> I do not I didn't tape I didn't grab a

2:02:04tape measure and um look at them. So I

2:02:07wouldn't be able to give you the exact

2:02:10uh square footage of them. I was talking

2:02:12about the pavement I would um in the

2:02:14main the main area which the park owner

2:02:17is responsible for and what their rent

2:02:19price was. Okay.

2:02:33Attorney Shenko, while you're doing

2:02:34that, I do have a question through the

2:02:36chair. Um, State Representative

2:02:38Martinez, uh, tab 8 in the complaintants

2:02:42binder shows pictures of water.

2:02:46Uh, did you take any of these pictures?

2:02:48>> I did not.

2:02:49>> Okay.

2:02:51>> Thank you.

2:03:09Do you know when those P do you do you

2:03:10know when those pictures were taken

2:03:12>> from the standing water in the binder?

2:03:14>> Tab eight. Tab eight.

2:03:15>> I'm sorry. I do not.

2:03:16>> Do you know who took them?

2:03:18>> I do not.

2:03:24There's nothing.

2:03:31Okay.

2:03:40>> Did I hear you correctly in your

2:03:41testimony that you mentioned a a water

2:03:43testing report?

2:03:46Yes, it was the I referred to it um with

2:03:50name 2023. It was um No, sorry. It was a

2:03:54DPH sanitary report.

2:03:57>> Is that in this materials?

2:03:59>> I didn't No, it's it's public record.

2:04:03>> I have no knowledge of this report. I

2:04:06asked my client and the maintenance uh

2:04:08head if they had knowledge of a report.

2:04:10We have no knowledge of a report that

2:04:12made any such adverse findings in the

2:04:13water. So, I'm I'm going to move to

2:04:15exclude any testimony or evidence about

2:04:17that.

2:04:18>> I'd be happy to forward it if somebody

2:04:20would like it.

2:04:21>> So, I I I can't rebut it. I don't I

2:04:23don't have it in front of me.

2:04:24>> Okay.

2:04:25>> So,

2:04:26>> we'll see if anyone else presents it.

2:04:29>> Okay.

2:04:34We we'll and I'll I'd move to make the

2:04:38witness available if that report does

2:04:40become available for additional

2:04:42questioning. Um, it was offered through

2:04:44her test, sorry, it was offered through

2:04:46her testimony. So, if it does become

2:04:48available, uh, we would allow it to come

2:04:51in, but I would move that it come in if

2:04:54you're available to testify to it.

2:04:59So, motion. I need a second.

2:05:02>> Second.

2:05:04>> All in f all in favor? I

2:05:06>> I

2:05:08>> Any opposed?

2:05:17You believe this commission should

2:05:19follow the relevant statutes pertaining

2:05:22to rent commissions in deciding whether

2:05:25rents are harsh and unconscionable,

2:05:28right?

2:05:28>> Absolutely.

2:05:29>> Are you aware there are 13 factors that

2:05:31that the commission is to consider?

2:05:33>> I am.

2:05:34>> Okay. And you think that they should

2:05:35consider all all 13 factors? Is that

2:05:37correct? This is different.

2:05:39>> I believe

2:05:40>> when I was reading it, I believe I

2:05:45Yes.

2:05:45>> the commission may consider all 13. Is

2:05:48that correct?

2:05:48>> Correct.

2:05:49>> Okay.

2:05:59>> The language the language is actually

2:06:01shall just to correct the record.

2:06:03>> Yeah.

2:06:06You mentioned Miss Jud and her home,

2:06:08correct?

2:06:08>> Correct.

2:06:09>> Previously. Okay.

2:06:10>> Okay.

2:06:15>> Are you aware that the landlord tried to

2:06:17contact her multiple times?

2:06:21>> No.

2:06:21>> To resolve the sit to resolve the

2:06:22emergency emergency situation.

2:06:24>> I never heard from anybody that um that

2:06:27the landlord had tried to contact her

2:06:30multiple times. When I reached out for

2:06:32extra supports for Miss Jud, I was able

2:06:34to contact her without an issue.

2:06:42>> Are you aware that the landlord

2:06:45requested access to the property

2:06:47multiple times to secure an emergency

2:06:50situation?

2:06:52>> I

2:06:53when I spoke with um Mrs. Jud,

2:06:58the utilities had been turned off on

2:07:01July 5th. Um on July 9 days later, it's

2:07:06hard to tell what that emergency

2:07:08situation

2:07:09would be 9 days after the fact.

2:07:14>> But you are aware that ultimately the

2:07:16landlord purchased Miss Jud's home,

2:07:18correct?

2:07:20ultimately. Um, but I I didn't have a

2:07:22chance to really ask Miss Jud follow-up

2:07:24questions as she was no longer

2:07:26discussing the issue after there was a

2:07:30meeting. So, I'm not sure what what was

2:07:32agreed to on her end, but she was no

2:07:34longer able to discuss the situation.

2:07:36>> Isn't it true the landlord purchased her

2:07:38home so it could take matters into its

2:07:41own hands and resolve an emergency

2:07:43emergency situation? Isn't that true?

2:07:46>> I don't believe that to be true. The

2:07:48landlord wasn't at the property and for

2:07:51a long period of time till after the

2:07:53storm. I don't know what emergency

2:07:55situation was being handled at that

2:07:57point.

2:07:59>> Right. We discussed that. Remember, Ever

2:08:00Source wouldn't allow them to access,

2:08:02but we'll move on.

2:08:03>> 9 days after that was

2:08:04>> we will move on.

2:08:05>> That was 4 days after they started their

2:08:07work.

2:08:08>> Isn't it true that you're up for

2:08:09re-election soon?

2:08:10>> I sure am.

2:08:11>> And what when's election day?

2:08:13>> November 3rd.

2:08:14>> Few weeks, right?

2:08:15>> Absolutely.

2:08:16>> Yes.

2:08:17Okay, I have no further questions.

2:08:20>> And can I just finish that thought on

2:08:22election day? Just that's he's

2:08:24>> Nope. He asked the question and that you

2:08:27answered it and that's it.

2:08:28>> Thank you.

2:08:35>> All right. So, we're move to redirect.

2:08:38There's nobody else questions.

2:08:40>> We You can redirect you you are allowed

2:08:43to redirect.

2:08:44>> Okay. You could give a a statement and

2:08:47>> Okay. Yeah.

2:08:48>> Additional testimony.

2:08:51>> Just Attorney Shankle will have an

2:08:52opportunity to to ask you any further

2:08:55questions though. Sorry. Attorney

2:08:57Shankle will have the opportunity to ask

2:08:58you any additional questions though.

2:09:00>> Yeah. I would just like the commission

2:09:02to note that some accusations were

2:09:04thrown out as soon as the attorney came

2:09:06up here about Eversworth stopping them

2:09:08and that wasn't actually showed in any

2:09:11of the evidence. my uh I am up for

2:09:15reelection. I'm finishing up my first

2:09:17term and I have focused a ton on mobile

2:09:20home law. I've passed a bill um in 24

2:09:23through the House um and passed a bill

2:09:26in 25 or sorry 25 and 26 both sessions

2:09:30uh through the house because I do have

2:09:32multiple manufacturer u mobile home

2:09:34parks in the district. Um, so I've been

2:09:38working on um this law, but the storm

2:09:40from July and the amount if um you can

2:09:45consider the amount that I've um been

2:09:47able to share. I've obviously spent a

2:09:49considerable amount of time um so it is

2:09:53um quite frankly it's insulting

2:09:57um to bring up um an election.

2:10:00>> Attorney Shankle, do you have any other

2:10:02questions?

2:10:03>> Thank you.

2:10:04>> Thank you.

2:10:07All right. So, we have the

2:10:08complaintant's next

2:10:10>> witness.

2:10:10>> Witness or or speaker

2:10:14represent.

2:10:16>> Was she already up?

2:10:19>> You were already up.

2:10:20>> Oh, I I don't get to say again.

2:10:22>> No,

2:10:23>> that's okay.

2:10:36You could feel free to present any

2:10:37evidence you want. I just want you to

2:10:39know that, you know, even based on

2:10:41what's been discussed.

2:10:42>> Thank you. I appreciate that.

2:10:44>> My name is Bobby Seir. I live in number

2:10:46nine. Um I have been at mobile home at

2:10:49Apple Denim or Apple Valley for about 10

2:10:52years now.

2:10:54And I will say that over the last

2:10:57probably year things have definitely

2:10:59gone um in a different direction. We

2:11:03don't know if it's the change of

2:11:04management and how things are being

2:11:06handled but we feel that there has been

2:11:08a lot of concerns when brought up as you

2:11:11will see in the notices that are sent. A

2:11:13lot of those notices are sent after a

2:11:15complaint is brought up whether it's a

2:11:17repair or um the road or the snow. Um,

2:11:22recently with the July 4th storm, we're

2:11:24talking about Eversource not allowing

2:11:26people in. I understand that lines down

2:11:29is a hazard. I come from a long family

2:11:32of bluecollar workers that work in

2:11:34electric electrical work, linesmen,

2:11:37steel workers, farmers. I understand

2:11:41that there are hazards that are in the

2:11:43way. However, when our next door

2:11:45neighbor has a full tree crew removing

2:11:48trees and actually said that they were

2:11:50going to call to offer to remove our

2:11:52trees and yet we had nobody show up,

2:11:56there begins to beg a question of

2:11:58response time because if there's already

2:12:01a full crew next door and there's nobody

2:12:03helping us, there's an issue.

2:12:06Now, when they did send people in for

2:12:08that tree work, there was one gentleman,

2:12:12one gentleman with a backpack blower and

2:12:15one gentleman with a chainsaw that came

2:12:17in. There were at least two to three

2:12:20very large trees down across the road.

2:12:26Myself,

2:12:27there are about three other people

2:12:29sitting in this crowd that are 65 and

2:12:32older that helped remove those trees.

2:12:36I'm talking trees the size of this. We

2:12:39were picking these up and moving them.

2:12:42So I understand about the you know ever

2:12:45source but there comes a point where you

2:12:47have to make questions. Not only that

2:12:49when they were there doing the work

2:12:52these men were sitting down most of the

2:12:54time they did they had inadequate

2:12:56equipment to actually remove everything.

2:12:59This took much longer. While our

2:13:01neighbors were done cleaning up, this

2:13:04process was ongoing for a very weeks

2:13:07weeks ongoing.

2:13:09I don't know where you come from, but

2:13:10where I come from, hard work is you work

2:13:12and you get the job done and you don't

2:13:14take advantage of people. I feel like

2:13:16the cost being charged for this was

2:13:20insurmountable. It took much longer than

2:13:22it really needed. the the status of the

2:13:25trees. If you look on tab eight, those

2:13:27the trees are one thing, but in tab

2:13:29eight, that's the ground whenever it

2:13:32does rain. I took those photos myself.

2:13:35That is every time it rains. Not a lot

2:13:38of rain. That is every single time it

2:13:41rains. One of our neighbors actually has

2:13:44an area where it rains so bad the cracks

2:13:48are there and grass is growing up under

2:13:50the cracks where her cars are.

2:13:53The cracks are crack sealed, but there's

2:13:55grass growing up through the cracks.

2:13:57There's tons of potholes throughout the

2:13:59place. And when we looked at the trees

2:14:00when they had fallen, you don't have to

2:14:03be an arborist to see what a rotted tree

2:14:05looks like. And there were quite a few.

2:14:11We are residents and we appreciate the

2:14:14land that we live on. We take care of

2:14:16our land. And how many times I've

2:14:19shoveled myself out, my neighbors out

2:14:22just for the snow crew to come and just

2:14:24plow us all back in.

2:14:27I understand there's a response time,

2:14:28but when other people and our neighbors

2:14:30are getting plowed out, when our

2:14:32neighbors are having tree work done,

2:14:33when our neighbors are having all of

2:14:34their stuff taken care of in a timely

2:14:36manner, but we're not, and we're being

2:14:40charged more and more and more,

2:14:43it comes to a point where we

2:14:46really need to

2:14:48think about where's the money going,

2:14:51what are we paying for?

2:14:55A lot of these people are elderly and on

2:14:56fixed incomes. They can't just pull

2:14:59another $88 out of the air. A lot of

2:15:02them are already using food banks and

2:15:05other options to try and make ends meet.

2:15:08We have people with severe medical

2:15:10issues

2:15:12who require oxygen 24/7.

2:15:15We have people here who when they want

2:15:19to make an complaint, they're terrified.

2:15:22They're terrified of repercussions. And

2:15:24I'm not saying that there will be

2:15:26repercussions, but it's just the tone

2:15:27that's been set.

2:15:31>> Miss or through the chair, uh, are you

2:15:33aware of anyone that has received a

2:15:35notice to quit?

2:15:37>> Notice to quit.

2:15:38>> Notice to quit uh the the property

2:15:41because they haven't paid a fine or

2:15:42anything like that.

2:15:43>> No, not to my knowledge. No. The only

2:15:46person that's ever been um expelled was

2:15:48was not due to any of those reasons.

2:15:52So I feel like and there's not

2:15:54>> and just one other question. Were any

2:15:56were anybody's income reported? I didn't

2:15:58see any income reported. We didn't miss

2:16:00that, right?

2:16:01>> No, I don't think we we didn't ask

2:16:02anybody for income. A lot of the time a

2:16:04lot of our elderly

2:16:05>> I just wanted to make sure I didn't want

2:16:07to interrupt. We have a lot of people

2:16:08who didn't want to um put in that

2:16:11information

2:16:12>> and understandably

2:16:14um but I just wanted to come up here and

2:16:16speak on as a human being behalf. You

2:16:18know, as someone who's been involved in

2:16:20this community for a long time, my

2:16:22husband and I helped take care of a lot

2:16:24of our neighbors when this happened. It

2:16:26brought us all together and it made us

2:16:28open our eyes to what's been going on

2:16:30around us and gave us the courage to

2:16:33really come together and um have deep

2:16:37conversations as a community about what

2:16:40the direction was going and why it was

2:16:43unfair and unconscionable for most of

2:16:46us.

2:16:48But now that's all I have to say though.

2:16:51>> Okay.

2:16:54attorney.

2:16:55>> Yeah, I just have a few questions.

2:16:56>> Sure.

2:17:02>> You mentioned your neighbors.

2:17:03>> I I need you to be on a mic. I'm sorry.

2:17:05We have to record.

2:17:07>> You mentioned your neighbors.

2:17:08>> Yes.

2:17:09>> Can you hear me? Okay.

2:17:09>> Uh, no, I can't.

2:17:11>> You mentioned your neighbors.

2:17:13>> Are those single family properties?

2:17:16>> Yes, they are.

2:17:17>> Okay.

2:17:18And would you agree that a single family

2:17:21home driveway is a lot smaller than an

2:17:25area a paved area the paved area at the

2:17:28mobile home part? It needs to be plowed.

2:17:31>> Um well the thing is is where these

2:17:33single family homes are is where mine

2:17:36is. I shovel all the way out to the road

2:17:40actually beyond the road. And I actually

2:17:43had the snow plow plow it under my car.

2:17:46>> It went under my car. Got my question

2:17:48though.

2:17:48>> Yeah. But yeah, no, I don't think that

2:17:50it's un, you know, unreasonable where

2:17:52the areas are that would be plowed. My

2:17:55uncle plowed roads. I feel like it would

2:17:57be very easy to do.

2:17:59>> But you you would agree that plowing a

2:18:02mobile home park is is a bigger job than

2:18:05plowing a typical single family.

2:18:07>> Oh yeah, absolutely. I absolutely agree.

2:18:09>> Okay. And you mentioned the arborist

2:18:12comparing the arborist crew um that

2:18:15cleaned up Dunham Mobile to your

2:18:17neighbor. Correct.

2:18:18>> Okay. Which neighbor are you referring

2:18:21to?

2:18:21>> The gentleman right to our right that

2:18:23had a h the tree fall right on top of

2:18:24the house.

2:18:25>> Okay. That was

2:18:25>> And there were multiple trees actually

2:18:27down. No, it wasn't a city.

2:18:28>> No, that was a single family house.

2:18:30>> Yes.

2:18:31>> Okay.

2:18:32Would you agree that the single family

2:18:34home property abudding the mobile home

2:18:36park is significantly smaller than the

2:18:40mobile home park?

2:18:41>> Not considering that what we were

2:18:42talking about is the main issue was the

2:18:45main trees that were down on the main

2:18:47thoroughfare for Eversource to get in

2:18:48there and they had just as much down.

2:18:51>> But it's a smaller property though,

2:18:52right?

2:18:53>> It's actually about the same size. It

2:18:54runs adjacent to the entire property,

2:18:56but only the driveway is one small

2:18:58driveway in.

2:18:59>> It's 5 and a half acres. Your neighbor's

2:19:01five and a half acres.

2:19:01>> The neighbor is right beside us.

2:19:03>> Single family home. Five and a half

2:19:04acres.

2:19:04>> I don't know if it's 5 and a half acres

2:19:06to be honest. I can't speak to that, but

2:19:07I know it runs adjacent to the entire

2:19:10property.

2:19:10>> Do you know how many trees the arborous

2:19:12crew removed of of your neighbor's

2:19:14property?

2:19:14>> I saw in your report that it said 23.

2:19:17And I would be interested.

2:19:18>> Not not Dunham, the neighbor.

2:19:19>> Oh, I don't know. How about the

2:19:20neighbor?

2:19:21>> Okay. Yeah.

2:19:21>> So, you don't know how many trees were

2:19:22removed?

2:19:23>> I do not.

2:19:24>> So, it could have been significantly

2:19:25less than Dunham. Is that correct?

2:19:27>> Okay.

2:19:28>> Okay. Okay. So, you really don't know

2:19:29how big or small the job was of your

2:19:31neighbors. Isn't that correct?

2:19:32>> No, I don't. I just know that they were

2:19:33able to get in before ours was.

2:19:35>> That's all. Thank you.

2:19:36>> Thank you.

2:19:38>> You have an opportunity to speak.

2:19:41>> Absolutely. I'm actually going to go

2:19:42ahead and call up um Dave Delore.

2:19:46He's the president of the Connecticut

2:19:48Manufactured Home Alliance. Um he's been

2:19:51um extensive experience advocating for

2:19:53manufacturer homes and he's been

2:19:56involved with Apple Valley residents as

2:19:57we've organized and looked for

2:19:59assistance regarding conditions

2:20:00management um because none of us knew

2:20:02where to turn. So he's been a really

2:20:04wealth of knowledge. So I would like to

2:20:05bring him up.

2:20:06>> Okay.

2:20:07>> Attorney Shankl, I would imagine you'd

2:20:09like to be heard.

2:20:10>> Yeah. I reiterate my objection from

2:20:12before, but I also object to the extent

2:20:14that Mr. Delhi or Delorei, I'm I'm

2:20:16sorry, I don't know how to pronounce

2:20:17your name, is acting inappropriately as

2:20:19a lawyer. Um, I don't know what he

2:20:21intends to testify or introduce, but

2:20:24obviously legal services need a license

2:20:25in the state of Connecticut. And to the

2:20:26extent that he's providing legal

2:20:28services, I object. To the extent that

2:20:30he's permitted to testify, I would

2:20:32request that he only testify as a fact

2:20:34witness, what he observed, not his

2:20:36opinion, not anything else. Okay.

2:20:41>> Is there Sorry through the chair. Is

2:20:43there a provision uh in 7-148 that

2:20:47prevents the commission from hearing uh

2:20:50from anybody who may not be a resident

2:20:53or may not have something to offer?

2:20:56>> I don't think there is. But to the

2:20:58extent that he's practicing law, there

2:21:01obviously statutes that pertain to the

2:21:03legal profession and it'll be

2:21:04inappropriate for Mr. Delorey to act as

2:21:08a legal representative of any of the

2:21:10tenants. Moreover, I would I would opine

2:21:13that putting that aside, the only

2:21:16relevant testimony for non-residents is

2:21:21witness testimony.

2:21:24So, if Mr. If if Mr. Deary is permitted

2:21:26to testify, the only thing that he

2:21:28should be permitted to testify is what

2:21:30he personally witnessed.

2:21:36>> If you want to make a motion, I'll

2:21:38>> Yeah. So, um, I'd like to make a motion

2:21:41that whatever he testifies is only

2:21:44pertinent to this to this case and what

2:21:46he's witnessed at the property.

2:21:49>> I'll second that.

2:21:51>> All in favor?

2:21:54>> I.

2:21:55>> And one more thing to put on the record,

2:21:56too. I also object to the extent that

2:21:57Mr. Delorei offers opinions on comps.

2:22:01Um, he's not a resident. There's

2:22:04actually case law that speaks to if

2:22:07you're a witness in court, you could

2:22:09offer expert testimony

2:22:11pertaining to the value of your property

2:22:13and you could talk about comps in your

2:22:15neighborhood. There's testimony there.

2:22:16There's case law to that effect. Mr.

2:22:18Deaherryy is not a resident, so he does

2:22:22not have that privilege and he's not a

2:22:24retained expert, so I don't think that

2:22:27any expert testimony should be allowed

2:22:29either. I'm just putting on the record.

2:22:31So through through the chair, um I

2:22:34understand what you're speaking about.

2:22:35You don't have to be an expert to

2:22:37testify as to the value of your own

2:22:39property. You'd have to be an expert to

2:22:41testify as to the value of somebody

2:22:42else's property. Um as far as your other

2:22:46the other matter practicing law without

2:22:47a license, that's not in front of us.

2:22:49That's not appropriately in front of us

2:22:51either. If you have a complaint, there

2:22:53are other avenues that you can file a

2:22:56complaint about that. Um there was, you

2:22:59know, several years ago that was an

2:23:00issue in Hamen. I don't know how that

2:23:02was resolved. Uh but you're free to take

2:23:05whatever action is necessary. Uh but uh

2:23:08the commission has moved to, you know,

2:23:10hear only testimony that's going to be

2:23:12relevant. if he offers,

2:23:15you know, values as to an opinion, uh,

2:23:18or his opinion as to what the values

2:23:20are, uh, I think the commission can hear

2:23:22that and, uh, the commission, you know,

2:23:24and the commissioners can use their own,

2:23:27uh, you know, knowledge and, you know,

2:23:29what we know is, you know, owning homes

2:23:32and and having seen things, uh, to

2:23:34determine whether or not we find Mr.

2:23:36Delh's testimony to be credible. And and

2:23:39the commission also does do annual

2:23:41studies. So we have our own annual study

2:23:43that we've done of comps in the area and

2:23:47for mobile homes you have to go a little

2:23:49further out. So we have that and

2:23:52available.

2:23:52>> Yep.

2:23:54>> Thank you.

2:23:54>> Yep.

2:23:56>> Mr. Delhi.

2:23:57>> Okay. Thank you for the opportunity to

2:23:58speak. My name is Dave Delorei. I'm a

2:24:00resident of Sun Cedar Springs Manufactur

2:24:02Community located just across Route 10

2:24:04from Apple Valley. I am president of the

2:24:06Connecticut Manufactured Homeowners

2:24:07Alliance, a volunteer group recognized

2:24:10in Connecticut General Statutes Chapter

2:24:11412 as being as being an advocate for

2:24:14the interests of of residents of mobile

2:24:16home parks. It's in the Connecticut

2:24:18statutes. Um, I am also a member of the

2:24:22DCP Mobile Manufactur Home Advisory

2:24:24Council uh for a number of years now.

2:24:26I'm a certified Connecticut general real

2:24:29estate appraiser um and a certified tax

2:24:32assessor. In my job, in those jobs, in

2:24:35the past, I have put values on mobile

2:24:38home parks in various jurisdictions

2:24:40around the state. Um, I've been asked by

2:24:42Apple Valley residents to speak on two

2:24:44issues relevant to their complaints

2:24:45before this commission. The first is

2:24:47tree maintenance at my park as well as

2:24:49amenities at my park versus Apple

2:24:51Valley. The differences are stark since

2:24:55p but since pictures tell a story better

2:24:57than words. I have photos of recent free

2:24:59work done at my park which also show the

2:25:01streets in my park and with your

2:25:04permission I'll distribute those

2:25:05pictures to you.

2:25:08>> Are they in the materials?

2:25:10>> I I I I was not part of the materials.

2:25:12They asked me to speak as a as a as a

2:25:14witness on on uh on on conditions in our

2:25:18park

2:25:19>> through the through the chair. Are the

2:25:20pictures of your park or this park?

2:25:22>> They are pictures of my park and you can

2:25:25compare them to your own your own

2:25:27knowledge of

2:25:28>> I I don't

2:25:29>> So part of what the commission had voted

2:25:31on was testimony that's relevant. I

2:25:34don't think pictures of trees at a

2:25:35different park are going to be relevant.

2:25:37>> Okay, I got it.

2:25:38>> So to describe them to you if I if I may

2:25:41finish.

2:25:41>> Sorry.

2:25:42>> Thank you. So to the extent that it

2:25:44pertains to the park and the facts of

2:25:46this case, uh please keep it to the

2:25:49facts of this case and comparing you

2:25:51know trees in other parks I don't think

2:25:53is necessarily going to help us in

2:25:55making a determination. You can go to a

2:25:58different park and there could be 100

2:25:59trees versus three trees somewhere else.

2:26:01So to that extent I would ask you to

2:26:02keep it to what your knowledge about

2:26:04this park is.

2:26:05>> All right. And I would just respond by

2:26:06there's always been already been

2:26:07testimony heard tonight of comparisons

2:26:09between the roads in in different parks

2:26:11from Apple Valley. Um so I will try to

2:26:14do it without the pictures. I have

2:26:16pictures in front of me of a I would say

2:26:19a four to six story crane mobile crane.

2:26:22>> Can I clarify the commission's order? Is

2:26:23it is it all even testimony evidence as

2:26:26well in addition to pictures about the

2:26:28trees? Because that's the way I

2:26:29understood it.

2:26:30>> Yeah. Yeah.

2:26:30>> Yeah. Okay.

2:26:31>> Yeah.

2:26:31>> I move to strike.

2:26:33We can't compare what what what

2:26:36Commissioner got is talking about. We

2:26:38can't make comparisons from one park to

2:26:40another as far as how they remove trees,

2:26:43what kind of trees were what what kind

2:26:45of trees were at your park versus their

2:26:47park. We could we could talk comps,

2:26:50which we will. I'm I'm assuming

2:26:52someone's you know, we've had some

2:26:54testimony about comps. Um, not much from

2:26:57this side, but we've had some, but not

2:27:00specific like this is how our park

2:27:03removed trees and how this park that has

2:27:05nothing to do with the rent.

2:27:07>> Okay. I I will try to refrain. I'm just

2:27:10going to say that if you as a commission

2:27:12are not familiar with the with the

2:27:14maintenance patterns in my park versus

2:27:17this park, Apple Valley, you'd not be

2:27:19doing your jobs. Um, but um I'll I'll

2:27:22just you stop me when when you think I'm

2:27:24going over the line. Well, just c can we

2:27:26stick to the relevance of this case? So,

2:27:28let what you know about their trees and

2:27:32their, you know, problems with their,

2:27:35you know, maintenance at at their comm.

2:27:37>> Well, I only know what I saw from the

2:27:39outcome of this the July 4 storm. I was

2:27:43there in immediate aftermath. As a

2:27:45matter of fact, um,

2:27:46>> so you can stick to testimony regarding

2:27:48>> I was there, let's see, the morning it

2:27:52took on took place on a Saturday. I was

2:27:54there the morning after because one of

2:27:56the homeowners who's already been

2:27:57mentioned, Jan and Jud, called me and

2:27:59asked me to come over. Um, there was a

2:28:01tree in her kitchen.

2:28:04There were multiple trees all over that

2:28:06park. Um,

2:28:09um, I bring up my park because they take

2:28:12a proactive

2:28:15>> We've already we've already ruled that

2:28:16you cannot mention your park.

2:28:18>> Okay.

2:28:19>> Thank you.

2:28:20>> Okay. a Haitian to add in addition to

2:28:23treat maintenance some residents benefit

2:28:25from a a recreation complex

2:28:28um including a clubhouse with a pool a

2:28:30library a workout center and a yoga room

2:28:32>> objection delahori did did you

2:28:35understand what the ruling of the

2:28:36commission was

2:28:37>> I don't know I there there's talk

2:28:39there's been talk about comparable about

2:28:41Liberty Park and a park over in Bristol

2:28:43>> so those are those are as to values and

2:28:45amenities tree removal is not something

2:28:48that we're addressing with regard to on

2:28:51an applesto apples uh basis here.

2:28:54>> Okay. Uh let me let me move on then. Um

2:28:57I didn't I said sun residents benefit

2:28:59from a recreation complex including a

2:29:02clubhouse with a pool, a library, a

2:29:04workout center, and a yoga room. Our

2:29:05roads are maintained much better than an

2:29:07Apple Valley. And we have curbside trash

2:29:09removal. These services are provided us.

2:29:12We just went up to 645. Our rent, my

2:29:14rent just went up to 645 this month um

2:29:17per month versus the 638 at Apple Valley

2:29:19that's being recommended. Despite our

2:29:22amenities, many of many of our residents

2:29:24who are in the room um struggle with our

2:29:26land rents and some of them are here

2:29:28tonight in solidarity because of the if

2:29:30the recent Apple Valley increases stand,

2:29:32it will give some excuse to raise our

2:29:34rents higher. I implore the commission

2:29:36to scrutinize this disparity in services

2:29:38and costs carefully and to rule that the

2:29:40proposed Apple Valley rent increases

2:29:41meet the harsh and unconscionable

2:29:43standard in state statutes. They also

2:29:46asked me about my experiences with one

2:29:50Apple Valley resident and the park owner

2:29:52as a result of the July 4th storm. Here

2:29:55I'll referred to a letter to the

2:29:56attorney general that I wrote on the

2:29:58matter.

2:29:59>> Is that is that letter before us? Sorry,

2:30:02through the chair. Is that letter before

2:30:04us? I do I do not know

2:30:06>> has

2:30:06>> I I I object. I I don't know what I'm

2:30:08dealing with here. I mean, is it being

2:30:10admitted to evidence or

2:30:11>> I

2:30:13This was kind of re referred to t t t t

2:30:15t t t t t t t t t t t t t t t t t t t t

2:30:15t t t t t t t t t t t t t t t t

2:30:15tangentially by attorney Shankle

2:30:16earlier. He said that he had been in

2:30:18conversations with DCP attorneys and DCP

2:30:21staff about the resident's complaints. I

2:30:24filed an attorney general's complaint.

2:30:26That's what this letter is. The attorney

2:30:27general in response referred the matter

2:30:30to DCP which is why this letter is

2:30:34relevant because that's how one of the

2:30:35things that DCP is operating on.

2:30:36>> Who was the complaint filed against

2:30:38through the chair?

2:30:39>> My my letter to DCP was I I don't know

2:30:43what I honestly don't remember. It was

2:30:45about this park and um and the and the

2:30:48actions that happened during the storm

2:30:50and um after the storm and as a result

2:30:54of

2:30:56uh park owner's actions.

2:30:59Were those were those letters submitted

2:31:01by the residents into in so that they

2:31:04could be

2:31:05>> I submitted them I submitted a complaint

2:31:06on their behalf as an advocate on

2:31:09>> understand. So did any did any of the

2:31:11residents submit that as evidence when

2:31:14they gave us the evidence. Is that in

2:31:16this?

2:31:16>> I don't know. I don't think No, I don't

2:31:18think so. No, it's my communications

2:31:20with the attorney general's office which

2:31:22was referred to DCP which is part of DCP

2:31:24investigation and I think attorney

2:31:25>> you're not one of the complaintants. I

2:31:27can't be a complaint res.

2:31:30I mean, just

2:31:31>> speaking on the record, I don't think

2:31:32I'd have any issue with it coming in,

2:31:34but I think that attorney Shankle would

2:31:36have to be provided with a copy of it

2:31:38along with all the commission members uh

2:31:40to be able to evaluate it. If you're

2:31:43offering it, if you're going to read it

2:31:44into evidence, then I want to actually

2:31:46have it as a piece of evidence.

2:31:48>> Thank you.

2:31:49>> I'm not sure I have an objection. I I

2:31:50don't know. I

2:31:52>> Well, he has to give you a pass. If

2:31:54>> he's going to enter into evidence, it

2:31:55has to be

2:31:56>> through through the chair. the

2:31:57representation is is that it was a

2:31:58letter that was sent to the attorney

2:32:00general on behalf of the complaintants.

2:32:03So to the extent that it it echoes some

2:32:05of the complaints that have been made, I

2:32:07have no issue having that come into

2:32:09evidence, I would move that it be

2:32:11allowed into evidence, provided that

2:32:13council has an opportunity to review it

2:32:16and cross-examine on it and it be

2:32:18provided at least with a copy to the

2:32:20commission this evening.

2:32:21>> I sorry I have I made six. I need one to

2:32:25read from. I can give attorney a copy.

2:32:28>> So I move I move to admit it as evidence

2:32:31on behalf of the complaintants.

2:32:36>> All in favor signify.

2:32:38>> I I I may have an objection to it

2:32:40coming. I don't I don't know if I have

2:32:41an objection or not. Didn't we agree?

2:32:44>> If you would like to review it, I I mean

2:32:46I I think if it was made as a complaint

2:32:48on behalf of the residents that we'd be

2:32:50able to have it come in. It's quasi

2:32:52judicial. the rules of evidence and

2:32:55procedure don't exactly apply and

2:32:58we would like to keep things moving as

2:33:00well.

2:33:02>> Yeah. And I would like to echo that. Um

2:33:06a lot of these objections are are

2:33:08applicable.

2:33:08>> Sir, there's no there's no there's

2:33:10nothing pending in front of you and and

2:33:12the extra commentary is not welcome.

2:33:14Okay.

2:33:15>> Sure.

2:33:16>> Thank you.

2:33:16>> Sir, do you have one more? You gave us

2:33:18four.

2:33:19>> I I so I had to give

2:33:21>> Here you go. I'll

2:33:22>> No, I don't need one. I'm sure you all

2:33:24have one.

2:33:25>> I I thought I had made six. Maybe I only

2:33:27made five. I'm sorry. I don't

2:33:28>> You're going to share, so we're good.

2:33:29>> All right. Um, dear Attorney General

2:33:31Tong, my name is Dave Delorey and I'm

2:33:32writing on behalf of Connecticut

2:33:34Manufacturers doing this.

2:33:35>> Yeah. Yeah.

2:33:37>> I need to review it. I'm going as fast

2:33:39as I can.

2:33:40>> Yeah. If council could please have a

2:33:41moment so that way you could review it.

2:33:43Thank you.

2:34:05I mean, I I do have an objection. I

2:34:07mean, this references a settlement that

2:34:09was made with Miss Jud and

2:34:11communications that were for settlement

2:34:13purposes only. Uh, you know, I This is

2:34:17not a complainant here. A lot of this is

2:34:19about Miss Jud,

2:34:21you know. So I so I object on on two

2:34:24basis. One, this is about a complainant,

2:34:26alleged complainant who's not before us

2:34:28anymore. Sheer complaint. Number two, it

2:34:30gets into all these details about

2:34:32settlement discussions with my client as

2:34:34you know in the rules of evidence that's

2:34:35protected. I I object.

2:34:37>> Okay. to to the extent that any

2:34:40reference to settlement and I have no

2:34:43problem

2:34:44striking the portions of settlement uh

2:34:47the complaints with with respect to the

2:34:50community I think I would like to hear

2:34:52but anything settlement related I'm you

2:34:55know I don't think any commission is

2:34:56going to take that into account or

2:34:58commissioner will take that into

2:34:59account. I certainly am not going to

2:35:01take that into account because Miss Jud

2:35:02is not a complaint in here and if there

2:35:04was a settlement that's not properly

2:35:07before us

2:35:08>> and also I can't cross-examine Miss Jud

2:35:10too. So

2:35:11>> So to the extent that the the exhibit

2:35:14makes reference to complaints uh it's in

2:35:18to the extent that it makes reference to

2:35:20any complaint at not here or to

2:35:22settlement discussions it'll be out

2:35:24instead of having to go through it line

2:35:26by line. Um, we're I think we're capable

2:35:30of understanding that.

2:35:31>> So, does the commission understand have

2:35:33any questions with what at uh

2:35:35Commissioner Gotautle's just mentioned.

2:35:39Okay,

2:35:41>> go ahead.

2:35:41>> All right. May I just preface my

2:35:43remarks? Every piece of information that

2:35:45I have in here was made with

2:35:47conversations with Miss Jud prior to

2:35:50whatever agreement she made

2:35:52>> with the park owner.

2:35:54>> So, Mr. Delhi, I you know I I think you

2:35:57might understand the rules of hearsay.

2:35:59Now we are allowed to take in hearsay,

2:36:02but I'm not going to take in any

2:36:03evidence of a settlement discussion. Ms.

2:36:06Jud is not here to be able as council

2:36:08aptly, you know, let us know to be

2:36:11cross-examined.

2:36:12>> You can stop me.

2:36:13>> So to the extent that the letter offers

2:36:16uh information about the complaints from

2:36:19the residents of the the mobile home

2:36:23park,

2:36:24>> they're in. Okay. But anything having to

2:36:26do with settlement discussions or

2:36:27anything having to do with Miss Jud that

2:36:28council cannot cross-examine is not

2:36:31going to be considered. Okay.

2:36:33>> Agreed.

2:36:34>> Thank you.

2:36:35>> Okay. Um I'm writing on behalf of the

2:36:38Connecticut Manufacturing Homeowners

2:36:39Alliance. As I stated before, the

2:36:40alliance is recognized under CGS chapter

2:36:43412 section 2184A as representing the

2:36:46interest of manufactured home park

2:36:47residents in Connecticut. I am

2:36:49contacting you about a serious matter

2:36:50affecting the rights of manufactured

2:36:52home park residents in our state.

2:36:54On Monday, June 30th, I met with Janet

2:36:56Jud, a resident of Donna Mobile Home

2:36:58Parks um uh aka Apple Valley in the

2:37:01kitchen of her home in Southernington.

2:37:03Miss Jud needed assistance filing a fair

2:37:04and commission complaint against her new

2:37:06park owner against her park owner

2:37:07permanent properties of Stanford. The

2:37:09complaint concerned a rent a proposed

2:37:11rent increase she received from

2:37:12management dated June 1st, 2026. She

2:37:15filed her complaint with the town of

2:37:16Sington sometime during the week

2:37:17preceding the July 4th holiday. On the

2:37:20evening of July 4th, a micro burst

2:37:21thunderstorm swept across Connecticut,

2:37:23causing severe damage in the park.

2:37:25Fallen trees knocked out the power for

2:37:27days. One tree fell across Miss Jud Miss

2:37:29Jud's home, running her home

2:37:30uninhabitable.

2:37:32Fortunately, she was at the other end of

2:37:34the home at the time and was not

2:37:35injured. Another tree fell on her car

2:37:37and her which her insurance company

2:37:39deemed a total loss.

2:37:41The next day, according to Miss Judge,

2:37:43she left Miss Jud left the message, the

2:37:44emergency contact number provided by the

2:37:46park owner, but did not receive a call

2:37:48back until the next day. It should be

2:37:50noted that some residents did not call

2:37:52the emergency number at all because a

2:37:53management letter dated January 26,

2:37:552026, warning that anyone calling the

2:37:57emergency number after hours for a

2:37:58non-emergency will be subject to a $350

2:38:01penalty. The park's emergency contact

2:38:03appears non-compliant with section 21824

2:38:06of the regulations of the state of

2:38:07Connecticut, which requires the park

2:38:09owner to establish a system so that

2:38:10residents can reach management at any

2:38:12time. The regulation states, quote, "The

2:38:15use of a telephone answering machine

2:38:17shall not be considered compliance with

2:38:18this section."

2:38:20On Monday, July 6th, an inspector from

2:38:23the Sington Building Department placed a

2:38:24notice on Miss Judge Misjudge's door

2:38:26stating that the home was unsafe and

2:38:28prohibited occupancy. State

2:38:30Representative Rebecca Martinez also

2:38:31visited the park that day to view the

2:38:32damage accompanied by US Senator Richard

2:38:34Blumenthal. Over the next 10 days,

2:38:36little progress occurred because Dunham

2:38:38Road was intermittently closed while

2:38:39Eversource worked to restore power.

2:38:42Sometime during the week of July 13th,

2:38:44the park owner received notice of Miss

2:38:45Jud's fair in complaint from the town of

2:38:47Sington. According to Miss Jud, on the

2:38:49afternoon of July 14th, park owner Peter

2:38:51Gray called her expressing sympathy for

2:38:53her situation.

2:38:53>> Mr. Delhorey, I'd like to stop you for a

2:38:55moment, if I may, through the chair. So,

2:38:57this section's entitled alleged

2:38:58retaliatory conduct. So, fair

2:39:01commissions are specifically

2:39:04allowed to look at retaliatory conduct

2:39:06as defined by the statute. That statute

2:39:09is 47A20

2:39:11of the general statutes. Is there

2:39:13anything in this letter before having

2:39:15you read it that falls within 47A20 of

2:39:18the general statutes?

2:39:19>> I will I think I'll let I'll defer to

2:39:21your judgment, sir.

2:39:23>> Uh well, I

2:39:24>> I don't know 47820 like you do. You're a

2:39:26fair commission member. Um but I would

2:39:28defer to your judgment. Okay.

2:39:30>> Can I just you now that I'm thinking

2:39:32about it after hearing more and

2:39:33reflecting I I think that offering this

2:39:35in violates the settlement agreement

2:39:36too. Um

2:39:38>> I well that nothing's been offered as

2:39:40far as what the settlement agreement is.

2:39:43It was it a confidential settlement

2:39:44agreement?

2:39:45>> I believe there was I mean I didn't know

2:39:47I didn't know that this was coming in

2:39:48tonight. So I believe there was

2:39:50confidential out confidentiality

2:39:51language in the agreement.

2:39:52>> Uh if you want to find out from your

2:39:54client, they're here. Now's the time.

2:39:57But under 47820, Mr. Delhi. Uh there's

2:40:02unless unless she was served with a

2:40:04notice quit for making a complaint

2:40:08there. I don't see any retaliatory

2:40:10conduct here.

2:40:12>> I'd like to interrupt. Um

2:40:14>> Mrs. Jud Mrs. Jud is not a complaintant.

2:40:17>> There was there there was

2:40:18confidentiality and other provisions

2:40:19that would prohibit this from coming in.

2:40:21>> And Mrs. Mrs. Jud is not a complaintant

2:40:24in this case. So

2:40:26>> if if you want I

2:40:27>> I'd like to I'd like to at least see

2:40:29something where it shows that there's a

2:40:31confidentiality provision in the

2:40:33complaint.

2:40:34>> Well,

2:40:34>> because if there isn't, then

2:40:37>> like I said, we we've already said that

2:40:40we're not going to hear anything with

2:40:41respect to any settlement.

2:40:43>> I'm sorry.

2:40:44>> This whole this whole

2:40:46>> thing is about Miss Jud.

2:40:48>> She's not complaining.

2:40:49>> All I can do is put up my phone. I I

2:40:50don't

2:40:51>> to the extent well to the extent that it

2:40:53discusses problems at the park that's

2:40:55>> I think that we can hear that testimony.

2:40:58>> Um but with respect to anything that is

2:41:01allegedly retaliatory where there's

2:41:04nothing in the statutory definition of

2:41:06it, we're we have to be strict with our

2:41:09interpretation of that. And unless

2:41:11there's something retaliatory in there,

2:41:13I think that heading is misleading.

2:41:14>> And it would have to be retaliatory

2:41:16against the complaintants that are here

2:41:18today, not Miss Jud because Miss Jud

2:41:20would have to bring her own retaliatory

2:41:22complaint before the Fair Rent

2:41:24Commission.

2:41:24>> But I I you know, again, I don't I can

2:41:26pull up hopefully quickly. I do believe

2:41:28there's language.

2:41:29>> I'll give you a moment to to pull that

2:41:30up. Um while you're pulling that up, Mr.

2:41:33Delhi did

2:41:34>> I mean can he

2:41:35>> I will apologize.

2:41:36>> Can you just summarize this? Let me let

2:41:37me let me see if I can stuck to the

2:41:40issues.

2:41:40>> I will apologize because this complaint

2:41:44was filed while um I well all the

2:41:48information was gathered while I could

2:41:49still talk to her. Okay. So the the

2:41:52problem is um the commission can never

2:41:54validate anything that's said because

2:41:58you can't talk to her because she's

2:41:59subject to a confidentiality agreement.

2:42:02>> There's a reason why they have those.

2:42:04>> Agreed. Agreed. So they went a be she

2:42:06went beyond this commission and that was

2:42:09her choice. Correct. To go beyond this.

2:42:10>> Well, I don't know what her choice was.

2:42:12She was she she she had legal counsel I

2:42:14believe.

2:42:14>> Okay. Well, she's not she's not a

2:42:16complaintant in this case, so I don't

2:42:17think

2:42:17>> All right. Let me just go back. Let's

2:42:19leave this. Just know I was provided

2:42:21correspondence on July 23rd that the uh

2:42:25complaint by Miss Jud was formally

2:42:27withdrawn.

2:42:28>> Okay.

2:42:28>> That's in your minutes from July 22nd.

2:42:31>> Right.

2:42:31>> Right.

2:42:32>> So, she's not a complaint.

2:42:33>> She's not a complaint. You're right. I'm

2:42:34sorry. Just I think

2:42:35>> so anything retaliatory against if there

2:42:37was retaliation alleged retaliation

2:42:40against Miss Jud.

2:42:42>> You could only Can you only speak on it

2:42:44as if you believe that someone here has

2:42:47been retaliated against? Because the

2:42:49case before us is not Mrs. Jud's case.

2:42:51>> I I get I understand what you're saying.

2:42:53So I I I think

2:42:54>> so we need to we need to wrangle this

2:42:56back in for time. I think what

2:42:59>> to what's going Excuse me for half a

2:43:01second to to the case that we the cases

2:43:03that we have in front of us. So if any

2:43:06of these complaintants believe that

2:43:08there was a retaliation against them,

2:43:10you could speak on that. But I don't

2:43:12believe Mrs. Mrs. Jud's

2:43:15testimony regarding Mrs. Jud should not

2:43:17even

2:43:18>> be presented unless as Commissioner

2:43:21Gotautle said it it's relatable to you

2:43:24know

2:43:25>> issues that have been raised at the

2:43:26park.

2:43:27>> Yes.

2:43:27>> All right. I I can only say that um

2:43:31alleged retaliation has been a concern

2:43:33of expressed by people that are subject

2:43:36tonight at this hearing. They've they've

2:43:38talked about retaliation. I uh let's

2:43:41see.

2:43:42>> We haven't heard

2:43:43>> um I let's see um where is where is it?

2:43:47Um

2:43:48on Monday, this is in the letter on

2:43:50Monday, July. This is not pursuant to

2:43:52her pursuant to her. It's what happened

2:43:54to me. Um,

2:43:56>> but you're not a complaintant either.

2:43:57>> Well, I received a notice. I just here

2:43:59you can make your minds up on that

2:44:00afterwards. I received a notice from no

2:44:02trespass from Mr. Gay's attorney, Edward

2:44:04Sinkle, threatening me with arrest if I

2:44:05set foot on any of Mr. Gay's properties

2:44:07in the future.

2:44:08>> I'll just leave it at that.

2:44:10>> Yeah, right. Mr. Delhi, if I if I may

2:44:12ask you about that. Um, are you familiar

2:44:15with how no trespass laws work?

2:44:17>> Um, generally.

2:44:19>> Okay.

2:44:20>> I was invited on the property that day.

2:44:22>> Okay. But you understand that we're not

2:44:25here to deal with a no trespass, but you

2:44:27you do understand that it's a private

2:44:29property and an owner of a property has

2:44:32the right to no trespass somebody.

2:44:35>> Is that Do you understand? I

2:44:36>> I would I I would agree with that. But

2:44:38however, that is something I brought up

2:44:40to DCP to address because if that stands

2:44:46then if I for example, I went into one

2:44:48of one of Mr. Gray's parks, the one in

2:44:50Brford,

2:44:51>> the

2:44:53Yeah. Well, we're starting to move

2:44:54beyond.

2:44:55>> We're not We're not here to litigate

2:44:56your your no trespass order. We're just

2:44:58here to determine whether or not the

2:44:59rent increase that

2:45:01>> was proposed by the landlord was harsh

2:45:03and unconscionable.

2:45:05>> All right. I would just say that um

2:45:07>> Attorney Shank, do you have

2:45:08>> I just had the language here that makes

2:45:10everything that he just testified to

2:45:13>> Well, he didn't really read the whole

2:45:14letter. He got cut off.

2:45:16>> Are we going to read it?

2:45:17>> If just the confidentiality provision,

2:45:19please. parties further agree that Jud

2:45:20will not assist, encourage, or

2:45:22participate in any way, shape, or form

2:45:24in any complaint brought by a third

2:45:27party against DMHP, which is done at

2:45:29Mobile Home Park, or any affiliate,

2:45:31including any complaints with the Fair

2:45:33Rent Commission of any town, Department

2:45:35of Consumer Protection, or any other

2:45:37government agency.

2:45:38>> What's the date on that?

2:45:40>> This was from

2:45:43July 22nd.

2:45:46And when and and that was and everything

2:45:48that is

2:45:49>> part of a general release

2:45:50>> everything being testified to

2:45:52>> be quite candid. It was to resolve like

2:45:54like all releases are to resolve the

2:45:56dispute finality. So we would not be

2:45:58here talking about misjudged complaint

2:46:00because my client spent a lot of time,

2:46:03energy, resolving the matter, buying the

2:46:05mobile home

2:46:06>> to the right to the extent that

2:46:08everything that is being represented was

2:46:10prior to that, uh, I don't think is, you

2:46:13know, I'm not going to pass judgment on

2:46:14whether or not there's a violation of

2:46:16that agreement. But I think Mr. Delhi

2:46:19has gotten his point across with respect

2:46:21to that. There are there were issues at

2:46:23the park. There still may be issues at

2:46:24the park. And that's the opinion that I

2:46:27understand he's giving because we're not

2:46:29accepting any opinion as to other parks

2:46:32or Miss Jud at this point because Miss

2:46:34Jud's not here and you cannot

2:46:35cross-examine her.

2:46:37>> So,

2:46:38>> but just to be clear, it says that Jud

2:46:39will Miss Jud will not assist any

2:46:40complaints,

2:46:41>> right? He's not Mr.

2:46:43>> He's not Miss Jud. So, that's, you know,

2:46:46but you're free to cross-examine him on

2:46:47that.

2:46:48>> Okay. every everything that I referred

2:46:50to actually I mentioned in the beginning

2:46:52everything that I referred to in this

2:46:53letter which went to the attorney

2:46:55general um and now it's part of the

2:46:57record of DCP is information that I

2:46:59gathered from her prior to the agreement

2:47:02he's referring to

2:47:03>> okay um can I is it can I proceed anyway

2:47:06or we or

2:47:07>> I mean is with respect with respect to

2:47:09the letter you know it's unless it has

2:47:12to do with how the park is being

2:47:15maintained

2:47:17pertaining to a rent increase. It's not

2:47:20going to be relevant to any decision

2:47:22that we'd have to make.

2:47:22>> I I can only testify to my I've been in

2:47:24their park. I've been to my park. I've

2:47:26been to the Little Valley Park that um

2:47:29it was referred to before. I've been to

2:47:31mobile home parks all across the state.

2:47:32Um there there are some that are better,

2:47:36then there are some that are worse.

2:47:39Okay. The pothole problem I think is is

2:47:43not typical. this the level of

2:47:46maintenance I don't believe is left

2:47:47typical. I think it I think both are

2:47:50substandard. Um and I invite the you

2:47:52know the uh attorney Shankle invited you

2:47:55to go to his to their park. I'm inviting

2:47:57you to come to my park and just drive

2:47:59through and see our see our our complex

2:48:02and see our roads and um and you can see

2:48:05what the trees look like even today

2:48:07compared to what they look like over

2:48:08there still.

2:48:10>> Okay. Um, last but not least, I guess,

2:48:12um, Tony Shenko's making reference to

2:48:16the part the property owner or Pyramid

2:48:20purchased um, Miss Jud's home. The

2:48:23purchase price was $0.

2:48:24>> Okay.

2:48:25>> It's in Miss Judge is not a complaint.

2:48:28We can't we can't stress enough that

2:48:30this is a judge.

2:48:31>> Attorney Shankle, do you have any

2:48:32questions for Mr. Delhi?

2:48:33>> Mr. Delhoy, let's see if he has any

2:48:35questions for you.

2:48:37>> Mr. Delhi, when was the last time you

2:48:39were at the at the property? Done a

2:48:40mobile home park.

2:48:42>> Um, just before I was no no tres just

2:48:44before I was no trespass.

2:48:46>> Approximately when was that?

2:48:47>> I just the date before your no trespass

2:48:49letter, sir.

2:48:50>> Talking June.

2:48:52>> Look at the date of your no trespass

2:48:53letter. That's the last I was there.

2:48:55>> Okay.

2:48:56>> I've driven by I've driven by there many

2:48:57times. I have never been on the property

2:48:59since the date of your letter.

2:49:00>> Okay. Okay.

2:49:02And is it so you you would not have any

2:49:05knowledge then about pothole repairs

2:49:06after your last visit. Is that correct?

2:49:09>> Only only if I could see it from the

2:49:10street.

2:49:11>> Okay. Just want to clarify that for the

2:49:12record.

2:49:16You mentioned that you pay now 6.45 per

2:49:19month at your current mobile home park.

2:49:21Is that correct?

2:49:21>> As of this month.

2:49:22>> And what's the name of that mobile home

2:49:23park again?

2:49:24>> Sun Cedar Springs.

2:49:26>> That's in Southernington, right?

2:49:27>> It's here in Southernington. Yes. Isn't

2:49:29it true that there are other lots that

2:49:30are higher rents?

2:49:32>> He's he's going to call with me about

2:49:33another another park.

2:49:34>> You you question me about another park.

2:49:37You told me you just told me you can't

2:49:39talk about it.

2:49:40>> You can't talk about what you're

2:49:42offering at your park. You they're

2:49:44offering comps. Okay. Asking you

2:49:46questions about what the

2:49:47>> true that some lots are more than 645.

2:49:51>> Absolutely not.

2:49:52>> Okay.

2:49:54>> We'll see what the evidence says. Okay,

2:49:55that's it.

2:50:01Okay.

2:50:02>> Yeah, they have to get sworn in. If they

2:50:03weren't um sworn in,

2:50:08>> you you've already testified.

2:50:10>> But how do we call another witness?

2:50:12>> Just whoever wants to testify, come on

2:50:14up.

2:50:14>> They could be a testifier, not a

2:50:15witness. Yeah. Is she she's on the list?

2:50:19Is she on She's a complaintant. Okay,

2:50:22perfect. And then she was not sworn in.

2:50:25Okay. So, we'll get her sworn in.

2:50:28>> Got the evidence.

2:50:30>> We have the bind you.

2:50:32>> We have We have the binders.

2:50:35>> Okay.

2:50:39>> Well, let's let's

2:50:40>> I I would like to just raise a Attorney

2:50:42Shankle. I would like to just raise an

2:50:44issue here. I mean,

2:50:46there's a lot of documentary evidence um

2:50:49outside of this letter. Have you had a

2:50:51chance to look at the rest of the binder

2:50:53to determine whether or not you have any

2:50:56objection to any of the documents coming

2:50:59in?

2:51:00>> Um my my plan was just to kind of take

2:51:02it as it comes. If it was offered, I

2:51:04would review it in more detail and see

2:51:05if I have an objection.

2:51:07>> Okay.

2:51:07>> Is that okay?

2:51:08>> That's fine.

2:51:14>> I Well, you can come back up after if

2:51:17you'd like to do that. I have no issue

2:51:19with that. But we're

2:51:20>> um

2:51:20>> but we to

2:51:22>> Can we get her sworn in?

2:51:23>> Swear in first.

2:51:24>> Yes.

2:51:25>> I think sworn in.

2:51:27>> No, she she wasn't. I wasn't sworn in.

2:51:29>> All right. Where's raise your right

2:51:30hand, please? Do you swear to tell the

2:51:31truth, the whole truth, and nothing but

2:51:33the truth? So, help you God.

2:51:34>> Yes.

2:51:35>> And just state your name and address for

2:51:37the record.

2:51:38>> My name is Mila Master. I live at 217

2:51:40Dunham Street, Unit 28.

2:51:43And

2:51:45first, before I go through all of the

2:51:47evidence, I just want to hand out

2:51:49packets of the remedies and relief that

2:51:52we're requesting. And I'll let everyone

2:51:55look through these as I'm going through

2:51:58the evidence binder. That way, you'll be

2:52:01able to see as we go through the

2:52:03evidence why these remedies that we're

2:52:06requesting are necessary.

2:52:08>> This is in addition to the binder.

2:52:11>> Yes.

2:52:14Thank you.

2:52:31>> Did you give a copy to the attorney?

2:52:33>> Yes.

2:52:37So, I'll kind of be going through tab by

2:52:39tab. And as a

2:52:44quick case summary,

2:52:47we just have the monthly common rent

2:52:51increasing by the 16%

2:52:55this term. And

2:52:58that is

2:53:00quite a jump compared to the last few

2:53:02years. And as stated previously,

2:53:07mobile homes, unlike the name, are not

2:53:10mobile. We don't have the ability to

2:53:12pack up and move. We don't have the

2:53:14ability to

2:53:17go anywhere else that we'd like to. All

2:53:20of our

2:53:22life is within our home.

2:53:24And if we want to go somewhere else,

2:53:27we'd have to go through the whole

2:53:28process of selling our house and then

2:53:33finding somewhere else as soon as we did

2:53:36sell that house.

2:53:38And

2:53:41if we start on tab one,

2:53:45we have a few different rental

2:53:47agreements

2:53:49and our June 1st renewal notice.

2:53:55and

2:53:57it'll show you what the rent was jumping

2:54:00to

2:54:02along with

2:54:04our new separate

2:54:07utility fees.

2:54:10And

2:54:11now we have our rent history.

2:54:18We also have the DAM mobile home park

2:54:21taxes from 2019 to 2025.

2:54:28And we also have the sewer bills from

2:54:32about 2014 to 2027.

2:54:36And we received these from town hall.

2:54:40And

2:54:43if they want to charge, Dana mobile home

2:54:46park wants to charge separate utilities

2:54:50for each of the residents,

2:54:53then

2:54:55we would need

2:54:58the taxes

2:55:01to actually line up with what's being

2:55:04shown.

2:55:08And

2:55:11if we do move over to tab two,

2:55:17we could look at the comparable mobile

2:55:20home parks that were talked about

2:55:23previously.

2:55:25And

2:55:28more information about each mobile home

2:55:31park and what they're offering is

2:55:34available in this tab.

2:55:36And we have some lower

2:55:41month per month mobile home parks as

2:55:44well as some higher mobile home parks.

2:55:48But the ones that are higher have

2:55:51amenities that are listed,

2:55:55ones that we don't have to justify the

2:55:58increases that we're receiving.

2:56:05Looking at tab three,

2:56:08we own our homes and we rent the lots

2:56:12and

2:56:142026 rules require us to maintain our

2:56:18homes and a substantial portion of our

2:56:21own lots. These include lawns, flowers,

2:56:25shrubs, and cleanliness of the yard.

2:56:28And a great difficulty of that is how

2:56:33can we maintain our outer portion of our

2:56:38lot in an orderly fashion if we don't

2:56:41know where our lot starts and ends.

2:56:44When we move in, we're never told

2:56:48where our house

2:56:51is ours, where it becomes our neighbors.

2:56:54We don't have fences that divide our

2:56:59houses from one house to the other.

2:57:03And

2:57:05if I

2:57:07don't mow part of my yard because I

2:57:10believe it's my neighbors, but then

2:57:13Pyramid comes and gives me a letter

2:57:16saying I'm going to get a $20 $25 fee

2:57:20for an unmaintained yard. And that's a

2:57:22$25 fee per day that it's not

2:57:25maintained.

2:57:29I'm just supposed to go and mow that

2:57:32part of a yard that I might believe is

2:57:35someone else's.

2:57:37And at least for me, the house next to

2:57:42mine has been vacant for a couple of

2:57:45months now. And that yard is overgrown.

2:57:51There's grass almost to

2:57:55my knees in some areas. I'm getting

2:57:57ticks when I walk outside.

2:58:00And

2:58:03when I

2:58:05pay a local high schooler to come mow my

2:58:07yard, I'm having them mow all the way to

2:58:12that house as well, even though I don't

2:58:14believe that area is mine because I

2:58:19don't want pests coming to my yard and

2:58:22getting on me when I go outside. I want

2:58:25to be able to go out into my yard in

2:58:27peace.

2:58:30And

2:58:33there are past rental agreements in Tab

2:58:363 as well.

2:58:38And

2:58:40one thing you can notice on past rental

2:58:43agreements,

2:58:44this has happened to me, this has

2:58:47happened to

2:58:49other residents who have moved in

2:58:53partway through a year

2:58:55where

2:58:57I moved in

2:59:00one month. Generally,

2:59:02our leases start during a summer month

2:59:06and that's when they begin. I moved in

2:59:11in November and receeded

2:59:19when I first moved in in 2023.

2:59:22And

2:59:24my lease says 12 months on it. That's

2:59:27when it says

2:59:29for

2:59:31that

2:59:32monthly rate in the year 2023,

2:59:36but then the next year around

2:59:40in the summertime, I'm hit with a new

2:59:42lease term that begins before November.

2:59:47I'm not getting a 12-ear lease, and I'm

2:59:49getting hit with a higher month-to-month

2:59:53term. But I can't go and get a lawyer to

2:59:58fight this for me cuz

3:00:01I'm mid20s. I have no money.

3:00:09Looking at tab 4,

3:00:13we have a notice January 26 about the

3:00:19emergency call line,

3:00:22$350 plus additional time charges.

3:00:27And

3:00:30nowhere in this letter does it state

3:00:32that this is for excessive use only.

3:00:38It just states that this is a fee for

3:00:44calling and true emergencies.

3:00:47But where's a true emergency to find?

3:00:50How do we know?

3:00:53And

3:00:54this makes people afraid to call because

3:01:00A, how are we going to afford the first

3:01:03$350?

3:01:05B. How long does something take to fix?

3:01:08Because

3:01:10Pyramid is slow to fix things in the

3:01:13first place.

3:01:15I know it's going to take more than an

3:01:17hour for whatever is broken when I call.

3:01:19So, I know the additional time will be

3:01:22charged as well if I am to call.

3:01:26>> Master, if I may just interrupt you for

3:01:27a moment. So, in the back of uh tab

3:01:30four,

3:01:32uh page 11, it's a sideways or landscape

3:01:35printout. Uh it shows emergency service

3:01:39charges, emergency call charge 350

3:01:42first. Is that in the lease or is that

3:01:45in a different document?

3:01:47>> What page are you looking at?

3:01:48>> Page 11 of the towards the back of tab

3:01:52four

3:01:54towards the bottom. It says emergency

3:01:56service charges and an amount.

3:01:58>> Were you provided that in the lease that

3:02:00you signed

3:02:02>> this document? Where did this document

3:02:04come from?

3:02:04>> This le uh this table that we made, this

3:02:08was created for this evidence binder.

3:02:12This is not part of our lease. No.

3:02:14>> Okay. Where does it say that you're

3:02:16being charged $350 for

3:02:19>> This came from a January 26, 2026 notice

3:02:23that was emailed and I believe mailed

3:02:26out to the residents of the park.

3:02:29>> That that's this first pa first page the

3:02:32first page of the binder or of tab 4.

3:02:35>> Yes.

3:02:37>> Can you can we give can you give us a

3:02:39second?

3:03:01And from what we have on the timeline,

3:03:03there is no $350 fee stated in the

3:03:06renewal for the 2026 disclosure.

3:03:10>> Okay. Thank you.

3:03:17On March 11th, we had the lot

3:03:20maintenance notice stating additional

3:03:22warnings

3:03:24would be sent or stating that no

3:03:26additional warnings would be sent until

3:03:29verifiable photo proof of cleanup was

3:03:32emailed to Mary, our park manager.

3:03:36And

3:03:38I can attest for me that

3:03:42I was concerned. My lot wasn't dirty,

3:03:46but I had a shovel out there. I had some

3:03:50gardening pots that

3:03:53were empty. I just had them out because

3:03:58I don't want dirt in my house. But

3:04:02does this count as unmaintained?

3:04:05I don't know. It's not specified.

3:04:08So, I went out in the rain and I went to

3:04:13spend time cleaning up moving my snow

3:04:17shovels, which are now in my bathtub in

3:04:20my second bathroom because I have no

3:04:22shed.

3:04:23And along with my

3:04:27uh snow ice melt that's also in my

3:04:31second bathroom bathtub because I have

3:04:33no shed.

3:04:36and my gardening pots, which I've since

3:04:40gotten rid of because I don't know what

3:04:43to do with them. But I went and did that

3:04:46in the rain because of a $25 a day

3:04:51charge that we were sent a notice for

3:04:56until photo proof could be sent over to

3:05:00Mary. and then I took a picture and sent

3:05:04it over

3:05:08on June 1st, 2026. The renewal renewal

3:05:13notice threatens daily fines relating to

3:05:15the lease return and loss of protections

3:05:20for not sending in the lease by a

3:05:24certain timeline.

3:05:26One important note on this is when we

3:05:29were emailed this lease return,

3:05:33we were emailed the first page and that

3:05:36was the page to sign.

3:05:39But that first page does not

3:05:43have that lease return loss of

3:05:45protections language.

3:05:48That loss of protections language is

3:05:50only on further pages that were then

3:05:54mailed out later on if you hadn't signed

3:05:57by a certain date and that date had

3:06:02passed for me by the time I received

3:06:05that mail.

3:06:07So when you first get that email, you

3:06:11don't know about that loss of

3:06:12protections that was hidden.

3:06:16Residents with oil tanks report a $25

3:06:19monthly tank charge

3:06:22and

3:06:24no report about policy is given to them

3:06:29for that tank insurance that they're

3:06:31paying.

3:06:34Residents ask the commission to consider

3:06:36these charges as part of the total

3:06:38economic burden

3:06:40for the evidence presented in these

3:06:43fines and fees.

3:06:49Page five, we have documents on the

3:06:53water reliability in the park.

3:06:57On January 5th, 2026,

3:07:01we have residents reporting low water

3:07:03pressure. On January 6, management

3:07:07notice sends out reports of a broken

3:07:11underground water pipe and planned

3:07:13shutdown for repair.

3:07:15On February 4th, residents report

3:07:19another low pressure event.

3:07:22On March 18th, management notice

3:07:24announces a March 20 shut off for

3:07:26underground tank work. March 20th,

3:07:30management notice states water fresh

3:07:33water would turn off from 9 to 11 for

3:07:36underground waterline repair. On July

3:07:3927th, residents report water loss of

3:07:43water during a storm.

3:07:46Management later reports a well pump

3:07:48contractor

3:07:50and electrician were being dispatched.

3:07:54And

3:07:56while

3:07:59it's been stated that these were brief

3:08:02events,

3:08:04residents are still going without water

3:08:06during these times.

3:08:09That well is our only access to fresh

3:08:12water. We have no city water to rely on

3:08:14and a backup.

3:08:19And also know this is 2026 alone,

3:08:25not considering all the other years with

3:08:30water issues that we're going through.

3:08:36On tab six,

3:08:40we can look and see that the March 20

3:08:45March 18th, 2026 rules state the park is

3:08:49responsible for maintaining and pruning

3:08:52large trees and large shrubs.

3:08:56We have residents documenting

3:08:59dead, damaged, and rotting trees from

3:09:02storm damage.

3:09:04The July 4th storm caused multiple down

3:09:07trees, power lines, and obstructed the

3:09:10park entrance.

3:09:13We have residents reporting tree cleanup

3:09:15began several days after the storm, and

3:09:18the debris remained for an extended

3:09:20period.

3:09:24And

3:09:26even still,

3:09:29with the park being cleaned up,

3:09:33we still don't even have a park entrance

3:09:35sign.

3:09:37A tree fell on it. It's not replaced

3:09:39yet.

3:09:41When I have people coming to my house,

3:09:44it's passed and I have people calling me

3:09:46asking where it is because there's no

3:09:50visible sign to show the park.

3:09:55And

3:09:58in terms of entering and exiting the

3:10:01park,

3:10:05there was a resident that was removed by

3:10:10emergency services on stretcher during

3:10:13that storm. But

3:10:16other residents also have to live in

3:10:19fear when

3:10:22this park is not accessible for an

3:10:27extended period of time.

3:10:31Ambulance concerns are a big deal. I

3:10:34myself am epileptic and if I have a

3:10:38seizure, I need to have an ambulance to

3:10:41be able to get to me. I need to go to a

3:10:44hospital and I need to see doctors.

3:10:49If I don't have that ability, I risk

3:10:53neurological issues.

3:10:56And

3:10:58the park not making anything accessible

3:11:03for extended periods is a danger not

3:11:07only to myself

3:11:09but the gentleman who needs oxygen along

3:11:12with many others.

3:11:20On tab seven, we have

3:11:25requests for rules making recycling

3:11:28mandatory and describing recycling

3:11:32service container requirements.

3:11:37Just this past week, we now have a

3:11:41sticker on the dumpster saying that it's

3:11:44cardboard only. But until last week,

3:11:48there was nothing indicating what could

3:11:50be there, what could not, whether that

3:11:53was a recycling dumpster. No one knew.

3:11:58Most of the rules and where things were

3:12:01in the park. I only learned because

3:12:06I bought my home from my uncle and

3:12:12he went around and showed me what rules

3:12:15were, where to access things.

3:12:18This information isn't in our lease.

3:12:21There's no information sheet when we

3:12:23move in sent to us by a park manager.

3:12:27We aren't told anything.

3:12:38On tab 8, we have

3:12:42pictures showing the damaged roads, the

3:12:45standing water, and the dam and the

3:12:47drainage problems.

3:12:50When I go and walk around in the park,

3:12:54I can step in puddles that go up to my

3:12:58ankle.

3:13:00And

3:13:01these puddles and

3:13:06divots in the park have been here since

3:13:10I moved in 2023.

3:13:14They're they've not been addressed. And

3:13:21they they are a safety concern. When

3:13:25it's the winter,

3:13:27they do turn to ice and it's dangerous

3:13:31to drive on. It's dangerous. When kids

3:13:35are outside

3:13:36playing,

3:13:38it's dangerous

3:13:42to

3:13:46walk on when people aren't looking

3:13:50necessarily where they're going and step

3:13:53in an area that's not flat.

3:13:59In terms of the snow removal,

3:14:03people shouldn't have to wonder if they

3:14:06could go to work in the morning because

3:14:13roads aren't plowed.

3:14:15The public road is plowed, but ours are

3:14:18not.

3:14:21Also,

3:14:23when the

3:14:25park plow does come eventually,

3:14:30it does not plow the entire park. The

3:14:34park has different areas. A large

3:14:37majority of it goes on a straight line.

3:14:42The unit where I'm at is near the end of

3:14:47the straight line and off onto an L

3:14:49shape.

3:14:51One time

3:14:53it didn't get plowed up until my house

3:14:56and I saw the plow driving away and

3:15:02walked out to him and asked about

3:15:06getting my area along with the two

3:15:09houses that go out onto the L. and he

3:15:13told me that he's only paid to plow the

3:15:17straight line and any other areas

3:15:21residents would have to hire a private

3:15:23plow. That's not his responsibility. And

3:15:26then he drove away.

3:15:29So then I was stuck there until a

3:15:34neighbor, her son or son-in-law, I'm not

3:15:38quite sure who,

3:15:40had plowed us out because I was stuck

3:15:42otherwise.

3:15:46There's also rodents and pests

3:15:49throughout the park because of trash

3:15:55and the dumpster not being emptied

3:15:58consistently.

3:16:00And I see these rodents quite often

3:16:06because

3:16:08there are

3:16:10a variety of cats throughout and

3:16:14thankfully they are mousers.

3:16:17So I see the evidence of the dead ones

3:16:28on tab nine.

3:16:30We have evidence that the emergency line

3:16:34routes to automated systems.

3:16:37We can't actually get a person to let

3:16:41know there is an emergency.

3:16:44And the whole point of an emergency line

3:16:47is because an emergency has occurred and

3:16:51to do something about that.

3:16:55If

3:16:57residents wanted to

3:17:00leave a message,

3:17:03we would be better off emailing.

3:17:07But

3:17:10emergency lines can't help us if no one

3:17:14is there or no one gets back to us.

3:17:23The lease also has a section on it that

3:17:28requests that residents

3:17:32report any

3:17:34issues within the park.

3:17:37And

3:17:39this isn't something a resident is

3:17:42likely to do when there is the $350

3:17:45emergency call charge.

3:17:52On tab 10, we have our

3:17:56privacy right of entry area.

3:18:00The 2026 rules and regulations

3:18:04contain a right of entry by park

3:18:06operator allowing entry for listed

3:18:09purposes.

3:18:11Previous rules and regulations did not

3:18:14include this new verbiage

3:18:18and residents state the utility shut off

3:18:23serving homes is outside. there's no

3:18:26need for park owners to enter inside the

3:18:30home.

3:18:32And we asked the commissioner to

3:18:34consider whether the scope of entry is

3:18:36appropriate in light of residents owning

3:18:38their homes

3:18:41as

3:18:43the park owner is able to complete any

3:18:47needed utility shut offs outside, not

3:18:51within the home.

3:18:53One last thing I would like to make a

3:18:56comment on is

3:18:59regarding the trees.

3:19:01It was mentioned before that

3:19:04a licensed arbor

3:19:07tree

3:19:09arborator has come out. The

3:19:14license as was mentioned previously

3:19:18is not valid.

3:19:21So no one license has come out for the

3:19:23trees

3:19:26and the requests that we have have been

3:19:30handed out.

3:19:33>> Thank you very much,

3:19:36>> attorney.

3:19:37>> I I have no questions. Um but I I do

3:19:39have uh just a general comment. Um I I

3:19:44raised this before. most of the issues

3:19:47that um this complainant has raised are

3:19:50are before the DCP and we provide a very

3:19:52detailed response. So I I kind of

3:19:55>> you could present that during your

3:19:57>> Okay.

3:19:59>> Okay.

3:19:59>> I I do have a question. So a couple of

3:20:01times sorry through the chair a couple

3:20:03of times reference has been made that

3:20:04the arburst is not properly licensed. Uh

3:20:08I don't have any evidence of of that. I

3:20:11don't know what part of the e-licens

3:20:13lookup was being reviewed. So the

3:20:16comments were made but if somebody has

3:20:17anything to state with regard to that

3:20:20please provide that. Uh I would imagine

3:20:23that you know a copy of a license and

3:20:26insurance would be sufficient from the

3:20:27arburst.

3:20:28>> Yes, I I can provide that. I I think

3:20:30what happened to double check there may

3:20:32be a typo on that document for the

3:20:34license number. That's my guess. Um

3:20:36>> or they may you know sometimes those

3:20:38sites when you're AIing it or googling

3:20:41it don't pull it up.

3:20:42>> I do.

3:20:43>> So we we'd have to have proof of that.

3:20:44So that's just an allegation and and the

3:20:46and the commission understands that's

3:20:48just alleged not licensed.

3:20:50>> Yes. I I think that could be easily

3:20:52verified.

3:20:53>> Yes.

3:20:53>> Um Mr. uh is you have nothing further? I

3:20:57know Mr. Delhi would like to come up and

3:20:59make a correction.

3:21:01>> No.

3:21:01>> Yeah. I I have no questions.

3:21:02>> No.

3:21:03>> Okay.

3:21:04>> Do the complaintants have any other

3:21:05witnesses they'd like to or

3:21:15>> this is a good place to rest and

3:21:17>> it's a good place to

3:21:18>> Yeah.

3:21:18>> stop for this evening. So, I think this

3:21:21is a good place to stop for this

3:21:22evening. Um,

3:21:24>> so, but I I would like to resolve an

3:21:26evidentiary issue with respect to the

3:21:28complaintants binder. Is there anything

3:21:30in here, Attorney Shankle, that is

3:21:32objectionable?

3:21:34>> I I don't think so.

3:21:36>> Okay. So, I would move to have the

3:21:37plaintiff's uh binder uh admitted as

3:21:42plaintiff's exhibit

3:21:45one with all the subp parts to it. And I

3:21:48would move to make that the full exhibit

3:21:51for the commission.

3:21:52>> So moved.

3:21:54>> Second.

3:21:55>> All in favor?

3:21:57>> I

3:21:57>> I

3:22:00>> um

3:22:02we just officially have to

3:22:05>> Yeah. I mean uh pursuant to 33 uh

3:22:10>> 334H in the event that there's

3:22:11insufficient time to complete a hearing

3:22:13or further cause commission shall have

3:22:14the power to adjourn the hearing to

3:22:16another date time and date.

3:22:18>> Okay. So we're not going to be able to

3:22:20get a date immediately because we have

3:22:23to check availability of this room. Um

3:22:26so we can notice the parties.

3:22:30We want to shoot for two weeks from now

3:22:33or

3:22:33>> Yeah. I mean, I'll

3:22:35>> on a Monday you generally it's open, but

3:22:37we can't

3:22:38>> I don't we don't have access in front of

3:22:40us to find out if the room is open. So,

3:22:42the hearing is going to continue because

3:22:45>> we're moving into, you know, 11:00 and

3:22:47I'm sure people want to go home.

3:22:48>> I also would ask through the chair, uh,

3:22:51Attorney Shankle is going to be putting

3:22:53on the respondents case. Um, do you have

3:22:57somebody that you will be examining his

3:23:00witnesses or cross-examining his

3:23:02witnesses? I don't think we're going to

3:23:05allow five people to get up and

3:23:07cross-examine a witness. Right.

3:23:09>> So, I think that you have time to

3:23:11>> you'll have time to decide how that's

3:23:13going to be handled.

3:23:15>> Okay. And so,

3:23:16>> oh,

3:23:18>> sorry.

3:23:18>> I just The only thing I mentioned in

3:23:20terms of scheduling, um, October 14th, I

3:23:23I can't do that day and I'd like to

3:23:24confer my client to get his schedule as

3:23:26well.

3:23:26>> Sure.

3:23:27>> Um, which date can't you do? I'm sorry.

3:23:29>> October 14th.

3:23:31I don't think I'm not I'm not even going

3:23:33to be here.

3:23:34>> When are you gone until

3:23:35>> that week?

3:23:36>> The whole week.

3:23:37>> The whole week and a half.

3:23:38>> So, I'm looking I'm looking to um

3:23:40potentially do for the 19th is what I'm

3:23:43hoping, but we don't know the

3:23:45availability of this.

3:23:46>> I'm not available.

3:23:48>> 19th

3:23:49>> 19th.

3:23:53>> What I can do is I can coordinate. Um,

3:23:55I've been going back and forth with uh

3:23:58Jennifer. Um, and I can coordinate with

3:24:03them to find dates that work for them

3:24:05and coordinate with everybody else too.

3:24:06>> Yeah. And then we have to find

3:24:07availability of the room. Okay.

3:24:09>> So, we can certain officially um

3:24:13>> how do we adjourn for the temporarily

3:24:16with the purposes of resuming?

3:24:18>> Okay. So, I' I'd like a motion to

3:24:21adjourn with uh Go ahead. You're going

3:24:23to make the motion.

3:24:24>> I'll make the motion. Uh motion to

3:24:26adjurnn and we'll come back at a later

3:24:28date.

3:24:30>> All in favor? I.

3:24:33>> Any opposed? All right. All right.