Louis Russo - Signed Reply to Objection of Motion for Summary Judgement.

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1. October 1st, 2015 the State of Connecticut implemented Public Act 15-236 “AN ACT PROTECTING ELDERLY CONSUMERS FROM EXPLOITATION”, (Exhibit 12, 4 pages) Specifically section 3 whereby the new law gives abused, neglected, exploited, or abandoned elderly persons a cause of action against their perpetrators and allows them to recover actual and punitive damages, costs, and reasonable attorney's fees. Additionally, it allows the defendant and or his advocate to take civil action, which the defendant has done in the filing of his appearance and Motion For Summary Judgment. 2. Additionally, Mr. Russo has not been deemed mentally insane nor has any party advised him of such a diagnosis despite his repeatedly denied and unfulfilled request for his medical records.

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