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AFFIDAVIT STATEMENT
To: State's Attorney
New Britain Superior Court
20 Franklin Square
New Britain, CT 06051
Subject: Affidavit Statement Regarding False Warrant and Allegations
Introduction
I, O'Rane M. Cornish Jr., bring forth this affidavit statement to address the false warrant and allegations
orchestrated by Officer Calvin Wentworth of the New Britain Police Department, with the intention to
harm me.
Factual Allegations
On Wednesday, April 24, 2024, Officer Calvin Wentworth was allegedly dispatched to investigate a
trespass complaint at 54 Helen Drive.
I was falsely accused of trespassing and assault by Dayris Delicastillo, a purported real estate agent who
was not present at 54 Helen Drive. There is no recorded conversation between Delicastillo and Officer
Wentworth, no signed affidavit, and no evidence of Delicastillo's existence. This lack of evidence raises
questions about the veracity of the accusations.
Prior to visiting 54 Helen Drive, I obtained permission from Erina Ponzini, attorney for Guardian Asset
Management. Officer Wentworth and Chief Marino are aware of the Federal Civil case at the US district
court of CT , titled Cornish Vs Guardian Asset Management. Erina Ponzini is Guardian Asset
Management’s attorney, she called ORane Cornish in march after being served by US Marshals and
consented to the Preliminary Injunction on the property at 54 Helen Drive in New Britain CT 06010. By
March the property had been ripped apart and rendered unlivable. Mr Cornish requested that Guardian
Asset Management provide another property, that he could use during this litigation . Erina Ponzi cited
that Guardian Asset has consented to the Preliminary Injunction and that would be the extent of their
courtesy for now. Erina Ponzi emailed the attached Email to the court registered Email for ORane M.
Cornish Jr , under Plaintiff:
Defendant: Guardian Asset Management, United States Department of Housing and Urban
Development, Grasso, Inthangsa and Dominguez
Case Number: 3:2023cv01612
Filed: December 11, 2023
Court: US District Court for the District of Connecticut
Presiding Judge: Sarala V Nagala
Referring Judge: Robert M Spector
Nature of Suit: Real Property: Other
Jury Demanded By: Plaintiff
Upon arrival, I was met in the street by Rene Sanchez-Morales, who confirmed my authorization to be
on the property. This was video taped , https://youtu.be/-SaccLX9gNM and confirmed by Morales I
handed him the document outside the property, asked to take photos , he consented. I asked some
questions, we shook hands and I left. This was a peaceful encounter, there was no disturbance or
assault, I’m not a violent person, this was fabricated by the officer in retaliation for the law suit filed
against his fellow officers by me, I was unlawfully evicted, I had paid taxes on the property, the electrical
and internet were on at the property in my name , I was communicating with the housing courts, HUD
and the New Britain Tax assessor’s office, while residing at 54 Helen Drive, New Britain Ct 06010 .
A copy of the suit is attached and signed by a federal Judge as Captain Don Anderson requested prior to
him retiring, the document was brought to New Britain police department by me and handed to the
desk officer who was aware that I was coming to the station at the request of Captain Don Anderson. He
said he would give the document to the Captain.
The officers have not been giving the New Britain States attorney the correct information
The photos taken on April 24th
2024, were to show the court the property is uninhabitable, so agreeing
to the consent to give me time work with HUD and to have paid the back taxes would be impossible. I do
not have the money to complete the renovation at that scale. I was told to research 203(k)
Rehabilitation loans. I’m currently homeless, HUD and the Tax assessor’s office in New Britain where I
paid on the taxes for 54 Helen Drive with the little money I had , after speaking to both of them had me
under the belief that I’d pay on the taxes, show the payments to HUD, and from there work something
out. I thought I’d be doing the renovation myself, while living there as it was liveable.
Officer Wentworth failed to acknowledge my legal authorization, constituting a Brady violation. I was at
New Britain Police department for almost 2 hours everything was documented on video
ORane M. Cornish Jr arriving at New Britain CT Police department on April 24th
2024 with the emailed
consent to Preliminary Injunction on Property at 54 Helen Drive New Britain CT 06010 from Attorney
Erina Ponzini : https://youtu.be/odZChxLKp_o?si=Cv-7argrNQJtCjSw
They had me at New Britain police department for almost two hours, I never asked for a police escort as
stated by Officer Wentworth in his falsified report as shown in the following video recordings :
Talking to Officer at NBPD about document consenting to occupation of 54 Helen Drive on April 24th
:
https://youtu.be/DBfSj5qrCnw?si=qfN5i9raOy3Hwnky
2nd conversation with Officer Cruz about Preliminary injunction at 54 Helen Drive :
https://youtu.be/4Ibp100US2Q?si=emUilRiQFbS6SZyO
Officer Wentworth submitted an affidavit containing misleading and inaccurate statements to obtain a
warrant for my arrest.
The affidavit omitted crucial information, including my legal authorization to access the property, as
evidenced by a preliminary injunction. Despite my attempts to provide evidence of consent, Officer
Wentworth disregarded this information.
Guardian Asset Management was served with a law suit in which I requested a preliminary injunction
on the property located at 54 Helen Drive in New Britain CT 06010 , Erina Ponzi Attorney for Guardian
Asset management consented to the terms specified in that law suit which is attached to this
affidavit. Those conditions were as follows:
1. Access to Property: ORane M. Cornish Jr requested access to the property located at 54 Helen Drive,
New Britain, CT 06053, without interference from Guardian Asset Management or any other party.
2.Duration of Access: ORane M. Cornish Jr requested access to the property for a period of 6 months.
3.Maintenance of Property: ORane M. Cornish Jr committed to maintaining the property in a well-
maintained, clean condition during the period of access, with all utilities under his name and paid for by
him.
4.Prevention of Homelessness: Denial of the injunction would force ORane M. Cornish Jr into
homelessness, rendering him incapable of maintaining his health, ability to work, and well-being. He
emphasized that he currently has no other residence.
5.Collaboration with Agencies: ORane M. Cornish Jr stated that he is actively collaborating with various
agencies, including 211, United Way, HUD (Housing and Urban Development), CAN (Community Action
Network), and the CT DSS (Department of Social Services), to address his housing situation.
6.Legal Protection and Recognition: ORane M. Cornish Jr emphasized the recent enactment of state
laws recognizing homelessness as a public health crisis and expanding protections for homeless
individuals under the Homeless Bill of Rights.
7.Court's Discretion: ORane M. Cornish Jr acknowledged the court's discretion to issue a temporary
injunction without requiring a bond when, for good cause shown, such a requirement would be
impractical or counterproductive.
Subsequent to the service of the complaint and the preliminary injunction request, Erina Ponzini,
representing Guardian Asset Management, voluntarily consented to these terms by email
communication to the registered email address provided in the court documents by ORane M. Cornish Jr
brigadetechnologies@yahoo.com.
Therefore, any entry onto the property by ORane M. Cornish Jr would not constitute trespassing, but
rather be in accordance with the terms outlined in the complaint and request for an injunction filed by
ORane M. Cornish Jr and served to Guardian Asset Management by US Marshals, whom New Britain
police officers Grasso , Dominguez and Inthosngsa claimed were the property owners when they
forcibly evicted Mr. Cornish in December knowing he had filed the civil suit against Guardian Asset
Management.
“Section 18 U.S.C. § 1001 prohibits knowingly and willfully making false statements, concealments, or
cover-ups. This means that the statement must have been made with the intent to deceive or mislead,
but it does not require an intent to defraud, which involves depriving someone of something through
deceitful means.
If a false statement or material omission is deemed to be material, it could result in the invalidation of a
warrant. This underscores the importance of honesty and transparency in legal proceedings, as any
falsehoods or significant omissions can have serious consequences for the validity of warrants and the
overall integrity of the legal process.”
Officer Wentworth was aware of my lawful presence at the police department, as documented by body
camera footage and lobby recordings. Despite this knowledge, he proceeded to issue the warrant based
on false premises. Entirely false
Officer Wentworth's report included details about my ethnicity and size, suggesting bias and potentially
racial motivation behind his actions. This behavior is indicative of systemic racism within the New Britain
Police Department.
Legal Argument
Officer Calvin Wentworth's actions constitute a violation of my Fourth Amendment rights.
The affidavit submitted by Officer Wentworth contained false statements and material omissions,
rendering the warrant invalid. The only person who told the truth as I have is Morales, and its nice to
know that he and I shook hands talked peacefully and parted ways in peace, as there was nothing to
fight over, and he told this to Officer Wentworth.
Officer Wentworth committed Brady violations by withholding evidence favorable to my defense.
Defendants' deliberate indifference to my rights and failure to conduct a proper investigation
demonstrate negligence and bias.
Conclusion
I respectfully request that Officer Calvin Wentworth be held accountable for his actions and that
appropriate measures be taken to rectify the harm caused by the false warrant and allegations.
I also request that whosoever wasn’t at the property and concocted a false story about me be arrested
for filing a false story if one was filed, of which one was not as there is no proof or evidence o one being
filed.
I am humbly requesting the warrant be invalidated as required by law, and being that I am homeless, I
do need the bond posted back as I am searching for housing and have committed no crime.
A report of what occurred is being sent to the FBI to document the occurrence.
Also I never intended to reoccupy the building, I was informed months ago the interior was ripped out
rendering the property uninhabitable, the photos were needed for court. I intend to pursue pressing
charges on each and every person responsible for the false warrant and arrest in this matter . The courts
were given all videos, documents and receipts in the matter of 54 Helen drive in my regard. As now all
documents have been handed over to The New Britain courts State’s Attorney for review.
I am due in court on the 17th
of May, this document will be delivered by me to the states attorney’s
office on Monday of May the 13th
2024. New Britain police department officers like to prank call me
sometimes the number the use is the same number that is monitored by the federal courts that number
is 917-242-0416 , my email is brigadetechnologies@yahoo.com, my mailing address is 18 Talmadge
street Bristol CT. I know New Britain Courts would never condone what occurred , but it happened and
it has now been brought to their awareness.
I would like to emphasize that I do need the bond back, I did nothing committed no crime and have
proof of it . I’m homeless; I could die at any given moment, but am trying my best to be the best I can
be. Police officers making up fake stories making me lose money when I am insolvent as is, doesn’t help
me, it just makes life worse. There is nothing I can do with the property as is. Please do not try to violate
my rights as officer Wentworth has. No warrant should have been issued or arrest made, there is no
evidence of any crime committed by me whatsoever, but there is overwhelming evidence of crimes
committed against me.
Every retaliatory act committed against me, will be reported to the FBI and other agencies that
watchdog over such behavior.
This affidavit is all I have to say regarding the matter
Thank you , Respectfully submitted
Executed this 11th day of May, 2024.
[Signature]
O'Rane M. Cornish, Jr.
18 Talmadge Street
Bristol, CT 06010
(917) 242-0416
Brigadetechnologies@yahoo.com
Re: Cornish v Guardian Asset Management (54 Helen Drive)
From: ORane Mansolin (brigadetechnologies@yahoo.com)
To: eponzini@gnpesq.com
Date: Friday, April 26, 2024 at 03:38 PM EDT
Understood, and the man who I'm talking to in the transcript
Transcript Worker : What happened with this house?
Plaintiff : The house was granted to me. You didn't know that? Okay, the house was granted to me.
Worker : Okay. (Plaintiff hands the worker a copy of the consent to the preliminary injunction)
plaintiff: Who do you work for? worker : Hmm ? Plaintiff : Who do you work for ?
Worker : For this company (worker points at the name of the company on the copy of the consent to the
preliminary injunction)
Plaintiff : Guardian asst?
worker : yes Worker : For this company.
Plaintiff: You can keep that. Do you mind if I take some pictures?
Worker : Yeah, take a picture. (worker agrees and motions it no problem for plaintiff to take photos of
the property inside and outside )
Plaintiff: Just show them that. So you got that. You got a copy of that. So they ripped out the whole
inside? (Plaintiff is making reference to the consent to the preliminary injunction paper work) Just what?
The bathroom and everything is out?
Worker: (yes)m,hm
Attorney Ponzini, how would you like to proceed ?as is evident the property is still occupied by Guardian
Asset Management after you agreed to a preliminary inunction in which Guardian Asset Management
was not supposed to be on the property as shown in the video.
Thank you
On Friday, April 26, 2024 at 02:53:05 PM EDT, Erina Ponzini <eponzini@gnpesq.com> wrote:
The preliminary injunction prevents Guardian Asset Management from gaining access to 54 Helen
Drive.
Erina R. Ponzini, Esq.
Gugliotta & Ponzini, P.C.
140 Huguenot Street, 2nd Floor
New Rochelle, NY 10801
5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive)
about:blank 1/5
914-813-1700 ext 1102
Fax: 914-813-1702
From: ORane Mansolin <brigadetechnologies@yahoo.com>
Sent: Friday, April 26, 2024 2:52 PM
To: Erina Ponzini <eponzini@gnpesq.com>
Subject: Re: Cornish v Guardian Asset Management (54 Helen Drive)
Good afternoon Attorney Ponzini
Your email granted the Preliminary injunction of which as specified in suit grants
access to 54 Helen Drive, are you now redacting consent ? Are you also
as well as citing that the man on this video attached does not work for Guardian
Asset Management as he so states on video recording? at 54 helen drive taking photos of
property
5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive)
about:blank 2/5
at 54 helen drive taking photos of property
The video will be made private again after it is viewed by you and you alone.
5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive)
about:blank 3/5
Are you saying the man in this photo is the property owner ? or HUD ? or are there attorneys who have been using
HUD and Gurdian Asset Management as a front to illigally claim property they have no right to in Connecticut ?
Thank you
On Friday, April 26, 2024 at 02:04:50 PM EDT, Erina Ponzini <eponzini@gnpesq.com> wrote:
It has been brought to my attention that you have been trespassing upon the property known as 54 Helen Drive
and telling the homeowner that I gave you permission to do so.
Be advised that permission has never been given by me, nor do I have the authority to give you this permission.
It has also been brought to light that HUD was the owner of 54 Helen Drive as of Dec. 2022 and HUD sold the
property to the new homeowners in Dec. 2023. Prior to HUD taking ownership, you are not named as the
homeowner.
Erina R. Ponzini, Esq.
Gugliotta & Ponzini, P.C.
140 Huguenot Street, 2nd Floor
New Rochelle, NY 10801
914-813-1700 ext 1102
Fax: 914-813-1702
From: Erina Ponzini
Sent: Thursday, April 18, 2024 12:19 PM
To: brigadetechnologies@yahoo.com
Subject: Cornish v Guardian Asset Management (54 Helen Drive)
Mr. Cornish,
Per our conversation, be advised that Guardian Asset Management herein consents to a preliminary injunction in
this matter.
5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive)
about:blank 4/5
Erina R. Ponzini, Esq.
Gugliotta & Ponzini, P.C.
140 Huguenot Street, 2nd Floor
New Rochelle, NY 10801
914-813-1700 ext 1102
Fax: 914-813-1702
5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive)
about:blank 5/5
January 17, 2024 Opinion or Order Filing 19 INITIAL REVIEW ORDER. Plaintiff brings this action
against Defendants Guardian Asset Management Company ("Guardian"), the U.S. Department of
Housing and Urban Development ("HUD"), and police officers Grasso, Inthangsa, and Dominguez. In
short, Plaintiff alleges that he was wrongfully evicted from 54 Helen Drive in New Britain, Connecticut,
and brings claims for violations of the Fourth, Fourteenth, First, and Eighth Amendments, as well as
negligence, negligent infliction of emotional distress, violations of local health and safety regulations,
and Connecticut homelessness statutes among others. The Court previously dismissed Plaintiff's original
complaint pursuant to 28 U.S.C. 1915(e)(2)(B)(ii) for failing to state a claim upon which relief may be
granted, and allowed Plaintiff the opportunity to amend his complaint to add factual detail. See ECF No.
11.First, the Court dismisses Defendant HUD from this action. In his second amended complaint, there is
only one factual allegation concerning acts or omissions by Defendant HUD: Plaintiff alleges that he
visited HUD, where an "admin assured him that if the taxes were paid, a resolution could be explored
wherein Plaintiff could own the property." ECF No. 17 at 4. This is insufficient to state a viable claim
against that Defendant. Defendant HUD is therefore dismissed, and the Clerk of Court is directed to
terminate Defendant HUD from this action. Next, the Court will allow Plaintiff's second amended
complaint to proceed against the remaining Defendants under 1915(e)(2)(B)(ii). Plaintiff's original
complaint was bereft of factual detail. In his second amended complaint, Plaintiff now describes how on
December 19, Defendant Guardian attempted to wrongfully evict him with the assistance of Defendant
Officers Grasso and Inthangsa. Id. at 4-5. Afterwards, Plaintiff returned to the property and resumed
living there until December 22, when Defendant Officer Dominguez assisted in a second (allegedly
wrongful) eviction. Id. 6-7. These allegations provide the minimal, but sufficient, factual detail to
proceed past initial review. Rule 4(m) of the Federal Rules of Civil Procedure provides that "[i]f a
defendant is not served within 90 days after the complaint is filed, the courton motion or on its own
after notice to the plaintiffmust dismiss the action without prejudice against that defendant or order
that service be made within a specified time." Defendants Guardian, Grasso, Inthangsa, and Dominguez
must be served by April 16, 2024. Plaintiff may request that the Court order the United States Marshals
Service to serve the complaint, in which case he will be responsible for providing service addresses for
the Defendants. See Fed. R. Civ. P. 4(c)(3). Any such motion should be filed by January 31, 2024.Plaintiff
is encouraged to consult the District of Connecticut's Guide for Self-Represented Litigants, which is
available on the Court's website, for helpful information about proceeding with a case pro se. Signed by
Judge Sarala V. Nagala on 1/17/2024.(Piccolo, Marissa)
February 1, 2024 Opinion or Order Filing 22 ORDER granting #21 Plaintiff's motion for service of
process. Pursuant to the Court's order at ECF No. 19, Plaintiff has requested that the United States
Marshals Service serve the complaint on the remaining defendants, as he is proceeding in forma
pauperis, and had identified those defendants' service addresses. See Fed. R. Civ. P. 4(c)(3). The Clerk
shall prepare service packets for the Marshals, who must effect service and file returns of service within
90 days of receipt of the service packets. The Marshals may serve Defendant Guardian Asset
Management as provided in Connecticut General Statutes Section 33-1219. Signed by Judge Sarala V.
Nagala on 2/1/2024. (Piccolo, Marissa)
UNITED STATES DISTRICT COURT for the District of Connecticut
Case No. 3:2023cv01612
AMENDED COMPLAINT AND REQUEST FOR INJUNCTION
I. The Parties to This Complaint
A. The Plaintiff(s)
O’Rane M. Cornish Jr
54 Helen Drive
New Britain, CT 06053
917-242-0416
Brigadetechnologies@yahoo.com
B. The Defendant(s)
Guardian Asset Management
2300 Lincoln Hwy Suite 700
Langhorne, PA 19047
United States Department of Housing and Urban Development (HUD)
United States
451 Seventh Street, SW, Washington, D.C
New Britain CT Police Officer Grasso in his individual capacity
10 Chestnut St, New Britain, CT 06051
(860) 826-3000
New Britain CT Police Officer Inthangsa in his individual capacity
10 Chestnut St, New Britain, CT 06051
(860) 826-3000
II. Basis for Jurisdiction
Federal Question
B. If the Basis for Jurisdiction Is Diversity of Citizenship
The Plaintiff(s)
a. If the plaintiff is an individual
The plaintiff, O’Rane M. Cornish Jr, is a citizen of the State of Connecticut.
The Defendant(s)
a. If the defendant is an individual
Guardian Asset Management is a foreign entity and is incorporated in Pennsylvania not Connecticut.
b. If the defendant is a government agency
United States Department of Housing and Urban Development (HUD) is a government agency.
c. If the defendant is a police officer
New Britain CT Police Officer Grasso and Officer Inthangsa are individuals acting under the color of law
as police officers for the New Britain Police Department.
3. The Amount in Controversy
The amount in controversy is more than $10,000, not counting interest and costs of court, because the
plaintiff is seeking relief to prevent harm, interference, and damages to his property and well-being. The
plaintiff asserts that the present value of the property, 54 Helen Drive, New Britain, CT 06053, is
estimated to be $75,000 or less due to severe neglect and infrastructural issues. The plaintiff, O’Rane M.
Cornish Jr, had been actively engaged in repairing the property, investing time and resources to address
its neglected state. The recent forcible eviction on or around 12/19/2023 at 3:30pm by New Britain CT
Police Officer Grasso and Officer Inthangsa has disrupted these efforts and poses a significant threat to
the property's value and Mr. Cornish's well-being.
III. Statement of Claim
A. Where did the events giving rise to your claim(s) occur?
The events giving rise to the claim occurred at the plaintiff's primary residence, 54 Helen Drive, New
Britain, CT 06053.
B. What date and approximate time did the events giving rise to your claim(s) occur?
In or around mid November 2023 and December 19, 2023
C. What are the facts underlying your claim(s)?
The plaintiff has been facing ongoing issues with Guardian Asset Management, including threats of
property interference and harm, leading to the need for the injunction. In or around late November
2023, Guardian Asset Management unlawfully entered 54 Helen Drive in New Britain, CT 06053,
breaking the newly installed locks by O'Rane M. Cornish Jr. Around this time, Mr. Cornish visited HUD
and spoke to an admin regarding property taxes. The admin assured him that if the taxes were paid, a
resolution could be explored. Shortly thereafter, Mr. Cornish made two payments—initially $500 and
then an additional $300.
Given Mr. Cornish's expertise in computer programs, hardware, and machines, having a residence is
crucial for his work and raising funds. However, 54 Helen Drive was in severe disrepair. While Mr.
Cornish was residing there, Guardian Asset Management damaged the water and heating pipes. Despite
the challenges, Mr. Cornish initiated cleaning and repair efforts. The original court case (Case Number:
3:2023cv01612) was filed as a preventive measure against the impending forcible eviction of Mr.
Cornish witnessed and videotaped by Mr. Cornish on 12/19/2023. On this date, a representative from
Guardian Asset Management broke into the home for the second time in 30 days, once again breaking
the locks, as evidenced in the provided photo.
When the Plaintiff pulled up after returning from Home Depot with the replacement pipes and sick with
pneumonia, plaintiff noticed the door lock was broken, took photos, and called the New Britain police
department. Plaintiff noticed a red Lexus parked in the street and took photos of it as well. Defendants
Officer Grasso and Officer Inthangsa of the New Britain police department arrived. Upon arrival, plaintiff
saw both officers talking to the man who broke the locks, a Guardian Asset Management representative.
Plaintiff approached the officers and handed them Case Number: 3:2023cv01612, explaining that the
individual who broke in is the one the federal complaint was filed against. It was mentioned that the
case is in court, and the judge asked for more detail regarding the situation.
Civil Rights Violations:
a. Illegal Eviction as a Violation of Due Process: Officer Grasso's involvement in the perceived illegal
eviction may constitute a violation of the plaintiff's civil rights, specifically the right to due process. If
proper legal procedures were not followed, it raises concerns about the plaintiff's entitlement to a fair
and lawful eviction process.
b. Failure to Consider Court Documents as a Denial of Access to Justice: Officer Grasso's alleged
dismissal of court documents and legal proceedings may be framed as a denial of the plaintiff's access to
justice. The failure to acknowledge and consider legal documentation suggests a disregard for the
plaintiff's right to present evidence and arguments in a fair and impartial legal proceeding.
c. Disregard for Personal Property as a Violation of Property Rights: Mishandling or inappropriate
handling of the plaintiff's belongings during the eviction could be presented as a violation of property
rights. Officers are expected to respect an individual's property rights, and any unwarranted
interference may be considered a breach of those rights.
d. Failure to Provide Adequate Notice as a Denial of Housing Rights: Officer Grasso did not follow
proper legal procedures or provide adequate notice; this was a denial of the plaintiff's housing rights.
Adequate notice is a fundamental aspect of fair eviction proceedings, and failure to adhere to this
requirement could be construed as a violation of the plaintiff's civil rights.
e. Dismissive Attitude towards Legal Documentation as a Violation of Equal Protection: Officer
Grasso's apparent dismissal of court documents and legal proceedings may be presented as a violation
of the plaintiff's right to equal protection under the law. If the plaintiff's legal claims were not treated
with the same level of consideration as others,
3c). Defendants Officer Grasso and Officer Inthangsa of the New Britain police department, saw the
complaint case# 3:2023cv01612 and were well informed of the situation and that the matter was in
court, and said that it is not proof that I live at the residents, they asked for an electric bill, I told them
the electricity was on in my name as was the internet, they then said that this still proves nothing. The
light bill was on in plaintiffs name, the internet is on in plaintiffs name, plaintiff called the police to
report that the residents were broken into unlawfully instead of assisting. Defendants Officer Grasso
and Officer Inthangsa of the New Britain police department forcibly evicted the plaintiff, putting him out
into the cold, citing that the man who broke in had a business card to identify himself. When Officer
Grasso was asked by Plaintiff if he was sure the Guardian asset management rep was who he said he
was, Officer Grasso responds on video saying "If he is wrong, then O'Rane should sue him". Plaintiff tells
Officer Grasso he does not want to sue him and again asks him to please understand that court
complaints were filed that will allow the dispute to be worked out in the courts. Officer Grasso refused
to acknowledge that the situation was in court and chose to unlawfully and forcibly evict the plaintiff
into the streets on 12/19/2023. The entire situation was recorded on video.
Due to the actions Defendants Guardian Asset Management, Officer Grasso and Officer Inthangsa of
New Britain CT police department all work plaintiff was doing to stabilize his living situation was done
has been halted. The defendants forced the plaintiff to load his belongings onto a pick up truck the
plaintiff has been repairing.
1. The Plaintiff seeks the injunction to prevent Guardian Asset Management from stealing or
interfering with any of the Plaintiff's property, person, or belongings for 6 months.
2. The Plaintiff is currently struggling with homelessness and residing at 54 Helen Drive, New Britain,
CT 06053, which is their primary residence.
3. Attached to this court filing is a copy of a receipt indicating the plaintiff paid past-due property taxes
for the address at 54 Helen Drive, New Britain, CT 06053.
4. Additionally, during the 6-month period of the requested injunction, the Plaintiff commits to
maintaining the property in question well-maintained, clean, and all utilities under the Plaintiff's name
and paid for by the Plaintiff.
5. Moreover, denial of the injunction would force the Plaintiff into homelessness, rendering them
incapable of maintaining their health, ability to work, and well-being. The Plaintiff currently has no other
residence.
6. The Plaintiff is actively collaborating with 211, United Way, HUD (Housing and Urban Development),
CAN (Community Action Network), and the CT DSS (Department of Social Services). The Plaintiff is also
working multiple side jobs to satisfy all debts required for the property, including taxes owed to the
town and HUD.
7. In accordance with Connecticut General Statutes (CGS):
- Under CGS § 17-273d, municipalities must provide emergency housing to General Assistance (GA)
recipients who become homeless for specified causes.
- CGS § 17-86e requires the Department of Income Maintenance to provide emergency housing
assistance to AFDC and state Social Security supplement program recipients who are made homeless for
specified causes.
- Under the Uniform Relocation Assistance Act (CGS § 8-266 et seq.), if the state or municipality
displaces a person, it must provide various forms of housing assistance.
- CGS § 17-619 mandates the Department of Social Services to establish a rent bank program to assist
families at risk of becoming homeless due to severe hardships.
8. The recently enacted state law, approved during the last legislative session, explicitly declares
homelessness a public health crisis, expanding protections for individuals experiencing homelessness
under the Homeless Bill of Rights established in 2013.
9. In accordance with the new state law, the Plaintiff emphasizes the critical recognition of
homelessness as a public health crisis and the expanded protections afforded to homeless individuals.
10. In furtherance of this recognition, the Plaintiff urges the court to consider the legislative intent
behind the recent law and its implications for individuals facing homelessness, reinforcing the urgency
and necessity of the requested injunction.
11. Considering the unique circumstances of homelessness, the Plaintiff respectfully requests the court's
understanding and flexibility in issuing the temporary injunction. As outlined in Conn. Gen. Stat. § 52-
472 (2021), the Plaintiff acknowledges the court's discretion to issue a temporary injunction without
requiring a bond when, for good cause shown, the court determines that such a requirement would be
impractical or counterproductive.
12. O'Rane M. Cornish Jr (Plaintiff) was illegally displaced and made homeless by the municipality of
Bloomfield CT, of which the case is currently filed and active in federal court Case #: 3:23-cv-01553.
IV. Irreparable Injury
The plaintiff is facing homelessness, and monetary damages at a later time would not adequately
compensate for the potential harm, interference, and damages to his property and well-being.
V. Relief
The plaintiff requests the court to issue a temporary restraining order immediately and schedule a
hearing for a preliminary injunction to address the issues raised in this complaint. The plaintiff seeks
protection of his rights and prevention of further harm.
VI. Certification and Closing
A. For Parties Without an Attorney
I agree to provide the Clerk’s Office with any changes to my address where case–related
papers may be served. I understand that my failure to keep a current address on file with the Clerk’s
Office may result in the dismissal of my case.
Date of signing: _______________
Signature of Plaintiff: _______________
Printed Name of Plaintiff: O’Rane M. Cornish Jr
B. For Attorneys
Date of signing: _______________
Signature of Attorney: _______________
Printed Name of Attorney: _______________
Bar Number: _______________
Name of Law Firm: _______________

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ORane M Cornish affidavit statement for New Britain court proving Wentworth's report was false and retaliatory

  • 1. AFFIDAVIT STATEMENT To: State's Attorney New Britain Superior Court 20 Franklin Square New Britain, CT 06051 Subject: Affidavit Statement Regarding False Warrant and Allegations Introduction I, O'Rane M. Cornish Jr., bring forth this affidavit statement to address the false warrant and allegations orchestrated by Officer Calvin Wentworth of the New Britain Police Department, with the intention to harm me. Factual Allegations On Wednesday, April 24, 2024, Officer Calvin Wentworth was allegedly dispatched to investigate a trespass complaint at 54 Helen Drive. I was falsely accused of trespassing and assault by Dayris Delicastillo, a purported real estate agent who was not present at 54 Helen Drive. There is no recorded conversation between Delicastillo and Officer Wentworth, no signed affidavit, and no evidence of Delicastillo's existence. This lack of evidence raises questions about the veracity of the accusations. Prior to visiting 54 Helen Drive, I obtained permission from Erina Ponzini, attorney for Guardian Asset Management. Officer Wentworth and Chief Marino are aware of the Federal Civil case at the US district court of CT , titled Cornish Vs Guardian Asset Management. Erina Ponzini is Guardian Asset Management’s attorney, she called ORane Cornish in march after being served by US Marshals and consented to the Preliminary Injunction on the property at 54 Helen Drive in New Britain CT 06010. By March the property had been ripped apart and rendered unlivable. Mr Cornish requested that Guardian
  • 2. Asset Management provide another property, that he could use during this litigation . Erina Ponzi cited that Guardian Asset has consented to the Preliminary Injunction and that would be the extent of their courtesy for now. Erina Ponzi emailed the attached Email to the court registered Email for ORane M. Cornish Jr , under Plaintiff: Defendant: Guardian Asset Management, United States Department of Housing and Urban Development, Grasso, Inthangsa and Dominguez Case Number: 3:2023cv01612 Filed: December 11, 2023 Court: US District Court for the District of Connecticut Presiding Judge: Sarala V Nagala Referring Judge: Robert M Spector Nature of Suit: Real Property: Other Jury Demanded By: Plaintiff Upon arrival, I was met in the street by Rene Sanchez-Morales, who confirmed my authorization to be on the property. This was video taped , https://youtu.be/-SaccLX9gNM and confirmed by Morales I handed him the document outside the property, asked to take photos , he consented. I asked some questions, we shook hands and I left. This was a peaceful encounter, there was no disturbance or assault, I’m not a violent person, this was fabricated by the officer in retaliation for the law suit filed against his fellow officers by me, I was unlawfully evicted, I had paid taxes on the property, the electrical and internet were on at the property in my name , I was communicating with the housing courts, HUD and the New Britain Tax assessor’s office, while residing at 54 Helen Drive, New Britain Ct 06010 . A copy of the suit is attached and signed by a federal Judge as Captain Don Anderson requested prior to him retiring, the document was brought to New Britain police department by me and handed to the desk officer who was aware that I was coming to the station at the request of Captain Don Anderson. He said he would give the document to the Captain. The officers have not been giving the New Britain States attorney the correct information The photos taken on April 24th 2024, were to show the court the property is uninhabitable, so agreeing to the consent to give me time work with HUD and to have paid the back taxes would be impossible. I do not have the money to complete the renovation at that scale. I was told to research 203(k)
  • 3. Rehabilitation loans. I’m currently homeless, HUD and the Tax assessor’s office in New Britain where I paid on the taxes for 54 Helen Drive with the little money I had , after speaking to both of them had me under the belief that I’d pay on the taxes, show the payments to HUD, and from there work something out. I thought I’d be doing the renovation myself, while living there as it was liveable. Officer Wentworth failed to acknowledge my legal authorization, constituting a Brady violation. I was at New Britain Police department for almost 2 hours everything was documented on video ORane M. Cornish Jr arriving at New Britain CT Police department on April 24th 2024 with the emailed consent to Preliminary Injunction on Property at 54 Helen Drive New Britain CT 06010 from Attorney Erina Ponzini : https://youtu.be/odZChxLKp_o?si=Cv-7argrNQJtCjSw They had me at New Britain police department for almost two hours, I never asked for a police escort as stated by Officer Wentworth in his falsified report as shown in the following video recordings : Talking to Officer at NBPD about document consenting to occupation of 54 Helen Drive on April 24th : https://youtu.be/DBfSj5qrCnw?si=qfN5i9raOy3Hwnky 2nd conversation with Officer Cruz about Preliminary injunction at 54 Helen Drive : https://youtu.be/4Ibp100US2Q?si=emUilRiQFbS6SZyO Officer Wentworth submitted an affidavit containing misleading and inaccurate statements to obtain a warrant for my arrest. The affidavit omitted crucial information, including my legal authorization to access the property, as evidenced by a preliminary injunction. Despite my attempts to provide evidence of consent, Officer Wentworth disregarded this information. Guardian Asset Management was served with a law suit in which I requested a preliminary injunction on the property located at 54 Helen Drive in New Britain CT 06010 , Erina Ponzi Attorney for Guardian Asset management consented to the terms specified in that law suit which is attached to this affidavit. Those conditions were as follows: 1. Access to Property: ORane M. Cornish Jr requested access to the property located at 54 Helen Drive, New Britain, CT 06053, without interference from Guardian Asset Management or any other party. 2.Duration of Access: ORane M. Cornish Jr requested access to the property for a period of 6 months.
  • 4. 3.Maintenance of Property: ORane M. Cornish Jr committed to maintaining the property in a well- maintained, clean condition during the period of access, with all utilities under his name and paid for by him. 4.Prevention of Homelessness: Denial of the injunction would force ORane M. Cornish Jr into homelessness, rendering him incapable of maintaining his health, ability to work, and well-being. He emphasized that he currently has no other residence. 5.Collaboration with Agencies: ORane M. Cornish Jr stated that he is actively collaborating with various agencies, including 211, United Way, HUD (Housing and Urban Development), CAN (Community Action Network), and the CT DSS (Department of Social Services), to address his housing situation. 6.Legal Protection and Recognition: ORane M. Cornish Jr emphasized the recent enactment of state laws recognizing homelessness as a public health crisis and expanding protections for homeless individuals under the Homeless Bill of Rights. 7.Court's Discretion: ORane M. Cornish Jr acknowledged the court's discretion to issue a temporary injunction without requiring a bond when, for good cause shown, such a requirement would be impractical or counterproductive. Subsequent to the service of the complaint and the preliminary injunction request, Erina Ponzini, representing Guardian Asset Management, voluntarily consented to these terms by email communication to the registered email address provided in the court documents by ORane M. Cornish Jr brigadetechnologies@yahoo.com. Therefore, any entry onto the property by ORane M. Cornish Jr would not constitute trespassing, but rather be in accordance with the terms outlined in the complaint and request for an injunction filed by ORane M. Cornish Jr and served to Guardian Asset Management by US Marshals, whom New Britain police officers Grasso , Dominguez and Inthosngsa claimed were the property owners when they forcibly evicted Mr. Cornish in December knowing he had filed the civil suit against Guardian Asset Management. “Section 18 U.S.C. § 1001 prohibits knowingly and willfully making false statements, concealments, or cover-ups. This means that the statement must have been made with the intent to deceive or mislead, but it does not require an intent to defraud, which involves depriving someone of something through deceitful means. If a false statement or material omission is deemed to be material, it could result in the invalidation of a warrant. This underscores the importance of honesty and transparency in legal proceedings, as any falsehoods or significant omissions can have serious consequences for the validity of warrants and the overall integrity of the legal process.”
  • 5. Officer Wentworth was aware of my lawful presence at the police department, as documented by body camera footage and lobby recordings. Despite this knowledge, he proceeded to issue the warrant based on false premises. Entirely false Officer Wentworth's report included details about my ethnicity and size, suggesting bias and potentially racial motivation behind his actions. This behavior is indicative of systemic racism within the New Britain Police Department. Legal Argument Officer Calvin Wentworth's actions constitute a violation of my Fourth Amendment rights. The affidavit submitted by Officer Wentworth contained false statements and material omissions, rendering the warrant invalid. The only person who told the truth as I have is Morales, and its nice to know that he and I shook hands talked peacefully and parted ways in peace, as there was nothing to fight over, and he told this to Officer Wentworth. Officer Wentworth committed Brady violations by withholding evidence favorable to my defense. Defendants' deliberate indifference to my rights and failure to conduct a proper investigation demonstrate negligence and bias. Conclusion I respectfully request that Officer Calvin Wentworth be held accountable for his actions and that appropriate measures be taken to rectify the harm caused by the false warrant and allegations.
  • 6. I also request that whosoever wasn’t at the property and concocted a false story about me be arrested for filing a false story if one was filed, of which one was not as there is no proof or evidence o one being filed. I am humbly requesting the warrant be invalidated as required by law, and being that I am homeless, I do need the bond posted back as I am searching for housing and have committed no crime. A report of what occurred is being sent to the FBI to document the occurrence. Also I never intended to reoccupy the building, I was informed months ago the interior was ripped out rendering the property uninhabitable, the photos were needed for court. I intend to pursue pressing charges on each and every person responsible for the false warrant and arrest in this matter . The courts were given all videos, documents and receipts in the matter of 54 Helen drive in my regard. As now all documents have been handed over to The New Britain courts State’s Attorney for review. I am due in court on the 17th of May, this document will be delivered by me to the states attorney’s office on Monday of May the 13th 2024. New Britain police department officers like to prank call me sometimes the number the use is the same number that is monitored by the federal courts that number is 917-242-0416 , my email is brigadetechnologies@yahoo.com, my mailing address is 18 Talmadge street Bristol CT. I know New Britain Courts would never condone what occurred , but it happened and it has now been brought to their awareness. I would like to emphasize that I do need the bond back, I did nothing committed no crime and have proof of it . I’m homeless; I could die at any given moment, but am trying my best to be the best I can be. Police officers making up fake stories making me lose money when I am insolvent as is, doesn’t help me, it just makes life worse. There is nothing I can do with the property as is. Please do not try to violate my rights as officer Wentworth has. No warrant should have been issued or arrest made, there is no evidence of any crime committed by me whatsoever, but there is overwhelming evidence of crimes committed against me. Every retaliatory act committed against me, will be reported to the FBI and other agencies that watchdog over such behavior.
  • 7. This affidavit is all I have to say regarding the matter Thank you , Respectfully submitted Executed this 11th day of May, 2024. [Signature] O'Rane M. Cornish, Jr. 18 Talmadge Street Bristol, CT 06010 (917) 242-0416 Brigadetechnologies@yahoo.com
  • 8. Re: Cornish v Guardian Asset Management (54 Helen Drive) From: ORane Mansolin (brigadetechnologies@yahoo.com) To: eponzini@gnpesq.com Date: Friday, April 26, 2024 at 03:38 PM EDT Understood, and the man who I'm talking to in the transcript Transcript Worker : What happened with this house? Plaintiff : The house was granted to me. You didn't know that? Okay, the house was granted to me. Worker : Okay. (Plaintiff hands the worker a copy of the consent to the preliminary injunction) plaintiff: Who do you work for? worker : Hmm ? Plaintiff : Who do you work for ? Worker : For this company (worker points at the name of the company on the copy of the consent to the preliminary injunction) Plaintiff : Guardian asst? worker : yes Worker : For this company. Plaintiff: You can keep that. Do you mind if I take some pictures? Worker : Yeah, take a picture. (worker agrees and motions it no problem for plaintiff to take photos of the property inside and outside ) Plaintiff: Just show them that. So you got that. You got a copy of that. So they ripped out the whole inside? (Plaintiff is making reference to the consent to the preliminary injunction paper work) Just what? The bathroom and everything is out? Worker: (yes)m,hm Attorney Ponzini, how would you like to proceed ?as is evident the property is still occupied by Guardian Asset Management after you agreed to a preliminary inunction in which Guardian Asset Management was not supposed to be on the property as shown in the video. Thank you On Friday, April 26, 2024 at 02:53:05 PM EDT, Erina Ponzini <eponzini@gnpesq.com> wrote: The preliminary injunction prevents Guardian Asset Management from gaining access to 54 Helen Drive. Erina R. Ponzini, Esq. Gugliotta & Ponzini, P.C. 140 Huguenot Street, 2nd Floor New Rochelle, NY 10801 5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive) about:blank 1/5
  • 9. 914-813-1700 ext 1102 Fax: 914-813-1702 From: ORane Mansolin <brigadetechnologies@yahoo.com> Sent: Friday, April 26, 2024 2:52 PM To: Erina Ponzini <eponzini@gnpesq.com> Subject: Re: Cornish v Guardian Asset Management (54 Helen Drive) Good afternoon Attorney Ponzini Your email granted the Preliminary injunction of which as specified in suit grants access to 54 Helen Drive, are you now redacting consent ? Are you also as well as citing that the man on this video attached does not work for Guardian Asset Management as he so states on video recording? at 54 helen drive taking photos of property 5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive) about:blank 2/5
  • 10. at 54 helen drive taking photos of property The video will be made private again after it is viewed by you and you alone. 5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive) about:blank 3/5
  • 11. Are you saying the man in this photo is the property owner ? or HUD ? or are there attorneys who have been using HUD and Gurdian Asset Management as a front to illigally claim property they have no right to in Connecticut ? Thank you On Friday, April 26, 2024 at 02:04:50 PM EDT, Erina Ponzini <eponzini@gnpesq.com> wrote: It has been brought to my attention that you have been trespassing upon the property known as 54 Helen Drive and telling the homeowner that I gave you permission to do so. Be advised that permission has never been given by me, nor do I have the authority to give you this permission. It has also been brought to light that HUD was the owner of 54 Helen Drive as of Dec. 2022 and HUD sold the property to the new homeowners in Dec. 2023. Prior to HUD taking ownership, you are not named as the homeowner. Erina R. Ponzini, Esq. Gugliotta & Ponzini, P.C. 140 Huguenot Street, 2nd Floor New Rochelle, NY 10801 914-813-1700 ext 1102 Fax: 914-813-1702 From: Erina Ponzini Sent: Thursday, April 18, 2024 12:19 PM To: brigadetechnologies@yahoo.com Subject: Cornish v Guardian Asset Management (54 Helen Drive) Mr. Cornish, Per our conversation, be advised that Guardian Asset Management herein consents to a preliminary injunction in this matter. 5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive) about:blank 4/5
  • 12. Erina R. Ponzini, Esq. Gugliotta & Ponzini, P.C. 140 Huguenot Street, 2nd Floor New Rochelle, NY 10801 914-813-1700 ext 1102 Fax: 914-813-1702 5/11/24, 11:13 PM Yahoo Mail - Re: Cornish v Guardian Asset Management (54 Helen Drive) about:blank 5/5
  • 13. January 17, 2024 Opinion or Order Filing 19 INITIAL REVIEW ORDER. Plaintiff brings this action against Defendants Guardian Asset Management Company ("Guardian"), the U.S. Department of Housing and Urban Development ("HUD"), and police officers Grasso, Inthangsa, and Dominguez. In short, Plaintiff alleges that he was wrongfully evicted from 54 Helen Drive in New Britain, Connecticut, and brings claims for violations of the Fourth, Fourteenth, First, and Eighth Amendments, as well as negligence, negligent infliction of emotional distress, violations of local health and safety regulations, and Connecticut homelessness statutes among others. The Court previously dismissed Plaintiff's original complaint pursuant to 28 U.S.C. 1915(e)(2)(B)(ii) for failing to state a claim upon which relief may be granted, and allowed Plaintiff the opportunity to amend his complaint to add factual detail. See ECF No. 11.First, the Court dismisses Defendant HUD from this action. In his second amended complaint, there is only one factual allegation concerning acts or omissions by Defendant HUD: Plaintiff alleges that he visited HUD, where an "admin assured him that if the taxes were paid, a resolution could be explored wherein Plaintiff could own the property." ECF No. 17 at 4. This is insufficient to state a viable claim against that Defendant. Defendant HUD is therefore dismissed, and the Clerk of Court is directed to terminate Defendant HUD from this action. Next, the Court will allow Plaintiff's second amended complaint to proceed against the remaining Defendants under 1915(e)(2)(B)(ii). Plaintiff's original complaint was bereft of factual detail. In his second amended complaint, Plaintiff now describes how on December 19, Defendant Guardian attempted to wrongfully evict him with the assistance of Defendant Officers Grasso and Inthangsa. Id. at 4-5. Afterwards, Plaintiff returned to the property and resumed living there until December 22, when Defendant Officer Dominguez assisted in a second (allegedly wrongful) eviction. Id. 6-7. These allegations provide the minimal, but sufficient, factual detail to proceed past initial review. Rule 4(m) of the Federal Rules of Civil Procedure provides that "[i]f a defendant is not served within 90 days after the complaint is filed, the courton motion or on its own after notice to the plaintiffmust dismiss the action without prejudice against that defendant or order that service be made within a specified time." Defendants Guardian, Grasso, Inthangsa, and Dominguez must be served by April 16, 2024. Plaintiff may request that the Court order the United States Marshals Service to serve the complaint, in which case he will be responsible for providing service addresses for the Defendants. See Fed. R. Civ. P. 4(c)(3). Any such motion should be filed by January 31, 2024.Plaintiff is encouraged to consult the District of Connecticut's Guide for Self-Represented Litigants, which is available on the Court's website, for helpful information about proceeding with a case pro se. Signed by Judge Sarala V. Nagala on 1/17/2024.(Piccolo, Marissa)
  • 14. February 1, 2024 Opinion or Order Filing 22 ORDER granting #21 Plaintiff's motion for service of process. Pursuant to the Court's order at ECF No. 19, Plaintiff has requested that the United States Marshals Service serve the complaint on the remaining defendants, as he is proceeding in forma pauperis, and had identified those defendants' service addresses. See Fed. R. Civ. P. 4(c)(3). The Clerk shall prepare service packets for the Marshals, who must effect service and file returns of service within 90 days of receipt of the service packets. The Marshals may serve Defendant Guardian Asset Management as provided in Connecticut General Statutes Section 33-1219. Signed by Judge Sarala V. Nagala on 2/1/2024. (Piccolo, Marissa)
  • 15. UNITED STATES DISTRICT COURT for the District of Connecticut Case No. 3:2023cv01612 AMENDED COMPLAINT AND REQUEST FOR INJUNCTION I. The Parties to This Complaint A. The Plaintiff(s) O’Rane M. Cornish Jr 54 Helen Drive New Britain, CT 06053 917-242-0416 Brigadetechnologies@yahoo.com B. The Defendant(s) Guardian Asset Management 2300 Lincoln Hwy Suite 700 Langhorne, PA 19047 United States Department of Housing and Urban Development (HUD) United States 451 Seventh Street, SW, Washington, D.C
  • 16. New Britain CT Police Officer Grasso in his individual capacity 10 Chestnut St, New Britain, CT 06051 (860) 826-3000 New Britain CT Police Officer Inthangsa in his individual capacity 10 Chestnut St, New Britain, CT 06051 (860) 826-3000 II. Basis for Jurisdiction Federal Question B. If the Basis for Jurisdiction Is Diversity of Citizenship The Plaintiff(s) a. If the plaintiff is an individual The plaintiff, O’Rane M. Cornish Jr, is a citizen of the State of Connecticut. The Defendant(s) a. If the defendant is an individual Guardian Asset Management is a foreign entity and is incorporated in Pennsylvania not Connecticut.
  • 17. b. If the defendant is a government agency United States Department of Housing and Urban Development (HUD) is a government agency. c. If the defendant is a police officer New Britain CT Police Officer Grasso and Officer Inthangsa are individuals acting under the color of law as police officers for the New Britain Police Department. 3. The Amount in Controversy The amount in controversy is more than $10,000, not counting interest and costs of court, because the plaintiff is seeking relief to prevent harm, interference, and damages to his property and well-being. The plaintiff asserts that the present value of the property, 54 Helen Drive, New Britain, CT 06053, is estimated to be $75,000 or less due to severe neglect and infrastructural issues. The plaintiff, O’Rane M. Cornish Jr, had been actively engaged in repairing the property, investing time and resources to address its neglected state. The recent forcible eviction on or around 12/19/2023 at 3:30pm by New Britain CT Police Officer Grasso and Officer Inthangsa has disrupted these efforts and poses a significant threat to the property's value and Mr. Cornish's well-being. III. Statement of Claim A. Where did the events giving rise to your claim(s) occur? The events giving rise to the claim occurred at the plaintiff's primary residence, 54 Helen Drive, New Britain, CT 06053. B. What date and approximate time did the events giving rise to your claim(s) occur? In or around mid November 2023 and December 19, 2023 C. What are the facts underlying your claim(s)?
  • 18. The plaintiff has been facing ongoing issues with Guardian Asset Management, including threats of property interference and harm, leading to the need for the injunction. In or around late November 2023, Guardian Asset Management unlawfully entered 54 Helen Drive in New Britain, CT 06053, breaking the newly installed locks by O'Rane M. Cornish Jr. Around this time, Mr. Cornish visited HUD and spoke to an admin regarding property taxes. The admin assured him that if the taxes were paid, a resolution could be explored. Shortly thereafter, Mr. Cornish made two payments—initially $500 and then an additional $300. Given Mr. Cornish's expertise in computer programs, hardware, and machines, having a residence is crucial for his work and raising funds. However, 54 Helen Drive was in severe disrepair. While Mr. Cornish was residing there, Guardian Asset Management damaged the water and heating pipes. Despite the challenges, Mr. Cornish initiated cleaning and repair efforts. The original court case (Case Number: 3:2023cv01612) was filed as a preventive measure against the impending forcible eviction of Mr. Cornish witnessed and videotaped by Mr. Cornish on 12/19/2023. On this date, a representative from Guardian Asset Management broke into the home for the second time in 30 days, once again breaking the locks, as evidenced in the provided photo. When the Plaintiff pulled up after returning from Home Depot with the replacement pipes and sick with pneumonia, plaintiff noticed the door lock was broken, took photos, and called the New Britain police department. Plaintiff noticed a red Lexus parked in the street and took photos of it as well. Defendants Officer Grasso and Officer Inthangsa of the New Britain police department arrived. Upon arrival, plaintiff saw both officers talking to the man who broke the locks, a Guardian Asset Management representative. Plaintiff approached the officers and handed them Case Number: 3:2023cv01612, explaining that the individual who broke in is the one the federal complaint was filed against. It was mentioned that the case is in court, and the judge asked for more detail regarding the situation. Civil Rights Violations: a. Illegal Eviction as a Violation of Due Process: Officer Grasso's involvement in the perceived illegal eviction may constitute a violation of the plaintiff's civil rights, specifically the right to due process. If proper legal procedures were not followed, it raises concerns about the plaintiff's entitlement to a fair and lawful eviction process. b. Failure to Consider Court Documents as a Denial of Access to Justice: Officer Grasso's alleged dismissal of court documents and legal proceedings may be framed as a denial of the plaintiff's access to
  • 19. justice. The failure to acknowledge and consider legal documentation suggests a disregard for the plaintiff's right to present evidence and arguments in a fair and impartial legal proceeding. c. Disregard for Personal Property as a Violation of Property Rights: Mishandling or inappropriate handling of the plaintiff's belongings during the eviction could be presented as a violation of property rights. Officers are expected to respect an individual's property rights, and any unwarranted interference may be considered a breach of those rights. d. Failure to Provide Adequate Notice as a Denial of Housing Rights: Officer Grasso did not follow proper legal procedures or provide adequate notice; this was a denial of the plaintiff's housing rights. Adequate notice is a fundamental aspect of fair eviction proceedings, and failure to adhere to this requirement could be construed as a violation of the plaintiff's civil rights. e. Dismissive Attitude towards Legal Documentation as a Violation of Equal Protection: Officer Grasso's apparent dismissal of court documents and legal proceedings may be presented as a violation of the plaintiff's right to equal protection under the law. If the plaintiff's legal claims were not treated with the same level of consideration as others, 3c). Defendants Officer Grasso and Officer Inthangsa of the New Britain police department, saw the complaint case# 3:2023cv01612 and were well informed of the situation and that the matter was in court, and said that it is not proof that I live at the residents, they asked for an electric bill, I told them the electricity was on in my name as was the internet, they then said that this still proves nothing. The light bill was on in plaintiffs name, the internet is on in plaintiffs name, plaintiff called the police to report that the residents were broken into unlawfully instead of assisting. Defendants Officer Grasso and Officer Inthangsa of the New Britain police department forcibly evicted the plaintiff, putting him out into the cold, citing that the man who broke in had a business card to identify himself. When Officer Grasso was asked by Plaintiff if he was sure the Guardian asset management rep was who he said he was, Officer Grasso responds on video saying "If he is wrong, then O'Rane should sue him". Plaintiff tells Officer Grasso he does not want to sue him and again asks him to please understand that court complaints were filed that will allow the dispute to be worked out in the courts. Officer Grasso refused to acknowledge that the situation was in court and chose to unlawfully and forcibly evict the plaintiff into the streets on 12/19/2023. The entire situation was recorded on video. Due to the actions Defendants Guardian Asset Management, Officer Grasso and Officer Inthangsa of New Britain CT police department all work plaintiff was doing to stabilize his living situation was done has been halted. The defendants forced the plaintiff to load his belongings onto a pick up truck the plaintiff has been repairing.
  • 20. 1. The Plaintiff seeks the injunction to prevent Guardian Asset Management from stealing or interfering with any of the Plaintiff's property, person, or belongings for 6 months. 2. The Plaintiff is currently struggling with homelessness and residing at 54 Helen Drive, New Britain, CT 06053, which is their primary residence. 3. Attached to this court filing is a copy of a receipt indicating the plaintiff paid past-due property taxes for the address at 54 Helen Drive, New Britain, CT 06053. 4. Additionally, during the 6-month period of the requested injunction, the Plaintiff commits to maintaining the property in question well-maintained, clean, and all utilities under the Plaintiff's name and paid for by the Plaintiff. 5. Moreover, denial of the injunction would force the Plaintiff into homelessness, rendering them incapable of maintaining their health, ability to work, and well-being. The Plaintiff currently has no other residence. 6. The Plaintiff is actively collaborating with 211, United Way, HUD (Housing and Urban Development), CAN (Community Action Network), and the CT DSS (Department of Social Services). The Plaintiff is also working multiple side jobs to satisfy all debts required for the property, including taxes owed to the town and HUD. 7. In accordance with Connecticut General Statutes (CGS): - Under CGS § 17-273d, municipalities must provide emergency housing to General Assistance (GA) recipients who become homeless for specified causes. - CGS § 17-86e requires the Department of Income Maintenance to provide emergency housing assistance to AFDC and state Social Security supplement program recipients who are made homeless for specified causes. - Under the Uniform Relocation Assistance Act (CGS § 8-266 et seq.), if the state or municipality displaces a person, it must provide various forms of housing assistance.
  • 21. - CGS § 17-619 mandates the Department of Social Services to establish a rent bank program to assist families at risk of becoming homeless due to severe hardships. 8. The recently enacted state law, approved during the last legislative session, explicitly declares homelessness a public health crisis, expanding protections for individuals experiencing homelessness under the Homeless Bill of Rights established in 2013. 9. In accordance with the new state law, the Plaintiff emphasizes the critical recognition of homelessness as a public health crisis and the expanded protections afforded to homeless individuals. 10. In furtherance of this recognition, the Plaintiff urges the court to consider the legislative intent behind the recent law and its implications for individuals facing homelessness, reinforcing the urgency and necessity of the requested injunction. 11. Considering the unique circumstances of homelessness, the Plaintiff respectfully requests the court's understanding and flexibility in issuing the temporary injunction. As outlined in Conn. Gen. Stat. § 52- 472 (2021), the Plaintiff acknowledges the court's discretion to issue a temporary injunction without requiring a bond when, for good cause shown, the court determines that such a requirement would be impractical or counterproductive. 12. O'Rane M. Cornish Jr (Plaintiff) was illegally displaced and made homeless by the municipality of Bloomfield CT, of which the case is currently filed and active in federal court Case #: 3:23-cv-01553. IV. Irreparable Injury The plaintiff is facing homelessness, and monetary damages at a later time would not adequately compensate for the potential harm, interference, and damages to his property and well-being. V. Relief
  • 22. The plaintiff requests the court to issue a temporary restraining order immediately and schedule a hearing for a preliminary injunction to address the issues raised in this complaint. The plaintiff seeks protection of his rights and prevention of further harm. VI. Certification and Closing A. For Parties Without an Attorney I agree to provide the Clerk’s Office with any changes to my address where case–related papers may be served. I understand that my failure to keep a current address on file with the Clerk’s Office may result in the dismissal of my case. Date of signing: _______________ Signature of Plaintiff: _______________ Printed Name of Plaintiff: O’Rane M. Cornish Jr B. For Attorneys Date of signing: _______________ Signature of Attorney: _______________ Printed Name of Attorney: _______________
  • 23. Bar Number: _______________ Name of Law Firm: _______________