SUPERIOR COURT

JUDICIAL DISTRICT OF HARTFORD

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THE BANK OF NEW YORK MELLON
v.
ROBERT STENHOUSE

REPLY TO OBJECTION TO STATE’S MOTION FOR
ORDERS TO ADDRESS IMPROPER DOCUMENTS

EXCERPT:

A court cannot award a foreclosing plaintiff relief unless that plaintiff comes to the court with “clean hands.” Here, there are no facts from which the court can conclude that the plaintiff acted with clean hands because the only facts before the court are that the plaintiff was aware in February of 2010 that its employees were routinely executing foreclosure affidavits without personal knowledge and outside the presence of a notary and that it was not until eight months later in October 2010 –

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