State of Connecticut Post Dates 02/10/2022 Payfile: 2200000-1 Judicial Dit of New Haven SUPERIOR COURT Tckets cvze50s27995 FILED Receipt Nbr 0643775 ean FEB 09 2022 CPS BOS27TAS RETURN DATE: MARCH 8, 2022 » SUPERIOR GOuRT 4" CHIEF CLERK'S OFFICE : HOLLY MASI, ZONING ENFORCEMENT : LD. OF NEW HAVEN OFFICER FOR THE TOWN OF HAMDEN, and TOWN OF HAMDEN ATNEW HAVEN Vv. JOSEPH ACCETTULLO, NEW ENGLAND CRAFT. CANNABIS ALLIANCE, and CAVALLARO fl ENTERPRISES, LLC : FERBAURY 8, 2022 APPLICATION FOR EX-PARTE TEMPORARY INJUNCTION AND ORDER TO SHOW CAUSE, Pursuant to Conn, Gen, Statute Section 8-12 and Section 52-471, et seq. and on the basis of the facts contained in the attached Verified Complaint, the Plaintiffs in the above-entitled action hereby make application for an ex-parte temporary injunction in accordance with their prayer for relief, and respectfully request that the Defendants, Joseph Accettullo, New England Craft Cannabis Alliance, and Cavallaro Enterprises, LLC, be enjoined ftom operating and/or maintaining a temporary cannabis bazaar at the property known as 18 Crest Way, Hamden, CT (the “property”) or any other location within the Town of Hamden without obiaining the necessary permits or approvals from the Hamden Planning & Zoning Commission, Quinnipiack Valley Health District, the Hamden Police Department, and/or the Hamden Building Department. ‘The Defendant Cavallaro Enterprises, LLC is the owner of the property known as 18 Crest Way in the Town of Hamden. The Defendant Joseph Accettullo is an individual residing at 60 Clover Circle in Hamden, CT. On information and belief, the Defendant Accettullo is the organizer of the “Cannabis Bazaar” and is a representative of the Defendant New England Craft Cannabis Alliance. On or about February 5 and 6, 2022 and various dates before, the Defendants Joseph Accettullo and New England Craft Cannabis Alliance held an event advertised as a “cannabis bazaar” at the property without obtaining any permits for a place of assembly from the Hamden Planning and Zoning ‘Commission pursuant to Sections 600, 610 and/or 724/of the Hamden Zoning Regulations. In addition, if iO |the Defendants did not obtain an Amusement permit from the Hamden Police Department pursuant to the Hamden Code of Ordinances, Sec. 112 and/or a Bazaar and Raffles Permit pursuant to the Hamden Code of Ordinances, Sec. 121. Because the Defendants did not apply for any permits, the Hamden Police Department was not formally notified and did not provide additional police protection as required by Connecticut General Statute Section 7-284. Upon information and belief, the Defendants served food and beverages without obtaining a permit from the Quinnipiack Valley Health District, which is the public health agency for the Town of Hamden. Approximately 500- 1000 people attended the cannabis bazaar throughout each day on February 5, 2022 and February 6, 2022. The amount of people, traffic, and parking created a threat to the public health, safety, and welfare, Hamden Fire Marshal Brian Dolan and Hamden Acting Building Official Carlo Sarmiento were denied access to the property on February 6, 2022 by the Defendant Accettullo. ‘The Fire Marshal and the Building Official have serious concems about the suitability of the building on the property for a large scale public gathering of several hundred people. The building on the property was constructed for storage of landscaping equipment. It does not meet the Building Code or Fire Code for a place of assembly. See Certificate of Occupancy attached hereto as Exhibit A. The Fire Marshal and the Acting Building Official were and are concemed about the means of ingress and egress to and from the building and whether the emergency vehicles would not be able to access the property in the event of an emergency. In addition, the Town of Hamden is concemed about whether there is adequate police to monitor a large event such as the “Cannabis Bazaar.” Upon information and belief, the Defendants, Joseph Accettullo, New England Craft Cannabis Alliance, and Cavallaro Enterprises, LLC, intend to hold additional cannabis bazaars at the property on February 12, 2022, February 13, 2022, and on a continuing basis thereafter. The Plaintiffs are concemed that the continued operation of the “cannabis bazaar” will pose an unreasonable threat to the public health, safety, and welfare. The Plaintiffs respectfully request that the Court issue an ex parte temporary injunction enjoining the Defendants from operating and maintaining a cannabis bazaar at the property until such time as they obtain the necessary permits from the Town of Hamden pursuant to Sections 600, 610 and/or 724 of the Hamden Zoning Regulations and Section 112 and/or 121 of the Hamden Code ofOrdinances. The Town of Hamden also requests that the Hamden Building Official, and the Hamden Fire Marshal be allowed access to the property for the purpose of inspecting the property for use as a place of public assembly. ‘THE PLAINTIFFS, HOLLY MASL-ZONING ENFORCEMENT OFFICER xGistant Town ATIORney 2750 Dixwell Avenue Hamden, CT 06518 (203) 287-7050 Juris: 26195epee habe AE 2 TOWN OF HAMDEN Office of the BUILDING OFFICIAL CERTIFICATE OF OCCUPANCY é Viemden, cr, AEE 21, 2005 found to substantially comply withthe provisions Stato of Comecticut Bese Building Code” and the purpose for which the building or structure as defined in Article 3 and 6 may be used Pied ints several pris as listed below. ‘Use Group & Occupancy. ‘Type of Construction. 1 Automatic Sprinkler System is provided, is it «roqured Sprinkler system? ‘The hazard classification or storage configuration, including aisle widths, for which the automatic sprinkler is designed. S - 1 Storage ‘The automatic sprinkler andior standpipe demand at the base of the riser, White Copy = Yellow Copy Department - Pink CopyCertificate # HAMDEN PLANNING DEPARTMENT ao Application For Certificate Of Zoning Compliance & Bond Reduetion/Release Request PROPERTY ADDRESS__|&7_Ceasir vases zonmne pistrict_/f=/ PROPERTY OWNER_\Viychee\ CaweW\evo TELEPHONE #_410 - S436 i PROPERTY OWNER ADDRESS 43. wacarter” €A7 loser. meen ‘TYPE OF ZONING PERMIT: _Cet ft nel ee {certify thatthe work required has been completed in accordance with approved plans except as noted on attached as-built deawings. APPLICANT SIGNATURE ‘PRINTED NAME, ADDRESS, - = ‘TELEPHONE #_Ylo “3436 FAX#_asY R952 “* ENGINEER CERTIFICATION: Tertfy that the work has been completed in accordance with approved plans except as specifically noted by notation on teens! ar utes pare_flpst 20,2005 ENGINEER SIGNATURE: DATE OF AS-BUILT DRA\ ab Based upon te inspection of: Ad jnconditional Certificate of Zoning “Conditional Cerificate of Zoning Compliance ‘See List Belo ‘The following is alist of requirements determined from inspectioa, which while not yet complete do not adversely affect the useloccupancy of the premises and for which suficient security is being held. Its the obligation of the property owner tonotfy the Planning Office when all items are complete and ready for inspection. Conditional certificates will expire ia ‘| ‘one year, Each inspection beyond the intial inspection requires a $100 fee. File Number (Bond Release Approved O Bond Reduction of $ Approved from to, (No Bond Belease/Reduction Approved Sign Fee a S Date Paid of as oS Date Receipn_OFYS7 . Rev. 429/06 ‘This is not a Certificate of Occupancy under the Building Code| zo HW | TOWN OF HAMDEN ADMINISTRATIVE ZONING PERMIT AND APPROVAL FOR APPLICATION FOR A BUILDING PERMIT “This permits hereby applied for in accordance withthe requirments of the Hamden Zoning Regulations Inland Wetlend Regulations, and other land use regulations as applicable, per plans attached. property anpress | Cres Olay Unmden bok 2/8 zone nistuct_N\~ | : prorsery owner ft Micheel Gavallere _ PHONES 410-186 - fovaD PROPERTY OWNER ADDRESS 32. ettlase «t /| 4 wentwer 26 Type ofPemit: _|/Afw Construction __Swinsting Pool _Change of Use _Addton_Other sign Excavation Fill Accessory Building/Structure Continuation Description of activity for which the permit is sought: J Sas\ai wih eat foo Av __shernye speidad fay Property Use: Single Family “\Commercia/Business Mixed Uses __ Non-profit SMstimily) india 2-3 Family other TeAablic Water = Well septic [sewer ‘This zoning permit and approval for sane of bling permit is base onthe plot plan and information submited by applicant “This permit subject toal conditions (if any) of approval, attached by any board/eommission and/or depariment of jurisdiction. Felsication by omision or misrepresentaigh, or fly to comply with the conditions of approval or record, hall cope ’ gpd ceres tnt property owner aproves ofthis aplication. ‘Applicant SIGNATURE PRINTED NAME ADDRESS Ud Witwhe er Bonn d Mehese Wr . TELEPHONE # 3436~ Ylo-2720 FAX et ag 3 ! Special Permit __Resubdivision —___ Subdivision cam. Tapz Flood Hazard Area substantia! Improvement ZBA Variance (3) #: Granted on: ‘A check mark indicates tht a signature i required. Permits not vali without all required signatures. Enginecring WPCA Town Engineer Date Quinnipiac Valley Health Authorized Agi. Date Fire Department Fire Marshall Date Inland/Wetlands we? Authorized Agt Date Lal PolceTrathic Authorized Ag, Date “Tax Department A tax Coliector Date Permit BGP RYE Office ‘Name TOWN OF HAMDEN ee et aera receipt “~igeas SEP 22 2004 i Resins Reviodt 7B DEP ~ Balding Pick Planing (Oo Engineering