Ledy J. Madero v. State of Connecticut Department of Revenue Services and Roberta Napoliano, Chapter 13 Trustee; Ledy J. Madero v. US Small Business Administration; City of Milford; Viora Inc. aka Sinclair; and Roberta Napoliano, Chapter 13 Trustee

CourtUnited States Bankruptcy Court, D. Connecticut
DecidedJanuary 23, 2026
Docket25-30973
StatusUnknown

This text of Ledy J. Madero v. State of Connecticut Department of Revenue Services and Roberta Napoliano, Chapter 13 Trustee; Ledy J. Madero v. US Small Business Administration; City of Milford; Viora Inc. aka Sinclair; and Roberta Napoliano, Chapter 13 Trustee (Ledy J. Madero v. State of Connecticut Department of Revenue Services and Roberta Napoliano, Chapter 13 Trustee; Ledy J. Madero v. US Small Business Administration; City of Milford; Viora Inc. aka Sinclair; and Roberta Napoliano, Chapter 13 Trustee) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Ledy J. Madero v. State of Connecticut Department of Revenue Services and Roberta Napoliano, Chapter 13 Trustee; Ledy J. Madero v. US Small Business Administration; City of Milford; Viora Inc. aka Sinclair; and Roberta Napoliano, Chapter 13 Trustee, (Conn. 2026).

Opinion

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT NEW HAVEN DIVISION

In re: Case No. 25-30973 (AMN) Chapter 13 Ledy J. Madero

Debtor Ledy J. Madero Movant

v.

State of Connecticut Department of

Revenue Services and

Roberta Napoliano, Chapter 13 Trustee Respondents RE: ECF No. 39 Ledy J. Madero Movant

US Small Business Administration; City of

Milford; Viora Inc. aka Sinclair; and

Roberta Napoliano, Chapter 13 Trustee Respondents RE: ECF No. 40

MEMORANDUM OF DECISION AND ORDER DENYING MOTIONS FOR FAILURE TO MEET DUE PROCESS REQUIREMENTS OF FED.R.BANKR.P. 7004

Service of a contested matter is governed by Fed.R.Bankr.P. 9014 and Fed.R.Bankr.P. 7004. Contested matters include motions to avoid a lien impairing an exemption pursuant to Bankrutpcy Code § 522(f) and motions to determine the secured status of a lien pursuant to Bankruptcy Code § 506. 11 U.S.C. §§ 506, 522(f). Practitioners should take note of the service requirements contained in Fed.R.Bankr.P. 7004(b)(4), (b)(5) and (b)(6) when serving federal, state and local governments because those service rules apply to respondents in contested matters. Here, Ledy Madero (the “Debtor”) filed two motions seeking relief pursuant to 11 U.S.C. § 506 to determine the claim status of liens asserted by the United States Small Business Administration (“SBA”), the City of Milford Tax Collector (“City Tax Collector”), and the Connecticut Department of Revenue Services (the “State DRS”)(collectively

“Respondents”). ECF Nos. 39, 40 (the “Motions”). Bankruptcy Rule 9014(b) applies to these contested matters and requires the movant to serve the motions on the respondents within the time prescribed by Rule 9006(d) and in the manner for serving a summons and complaint provided by Rule 7004. Fed.R.Bankr.P. 7004, 9006(d), 9014(b). As a rule of thumb, if a motion requires a caption identifying a movant and a respondent, it is most likely a contested matter and Fed.R.Bankr.P. 7004 applies to service of the motion. Motions that do not commence contested matters (e.g., employment applications, fee applications, and motions for extension of time, among others) are governed by Rule 9013. Fed.R.Bankr.P. 9013. The distinction is important because "service" under Rule 9013 requires mailing a notice using the address on the list

of creditors for the case or as identified in a proof of claim, while "service" under Rule 9014 is more akin to serving process in state or federal court litigation involving a plaintiff and defendant. Compare Fed.R.Bankr.P. 9013 and 2002(g) with Fed.R.Bankr.P. 9014(b) and 7004. How to Serve an Agency of the United States Pursuant to Fed.R.Bankr.P. 7004(b)(4) and (b)(5), service upon the United States and officers or agencies of the United States, such as the SBA, can only be accomplished by mailing a copy of the contested matter to all three of these addresses: (1) the address of the federal officer or federal agency; (2) the address for the United States Attorney's Office in the District where the action is filed, to the attention of the Civil Process Clerk; and (3) the Attorney General of the United States in Washington, D.C. How to Serve an Agency of the State of Connecticut or a City Tax Collector With respect to state and municipal public entities like the State DRS and City Tax

Collector, Rule 7004 requires a movant to mail the contested matter to the person or office prescribed by state law to be served or, if there is no such designation, then to the chief executive officer of the particular entity. Fed.R.Bankr.P. 7004(b)(6). To serve a city tax collector, Conn.Gen.Stat. § 52-57(b)(5) requires service “upon [the city’s] clerk, assistant clerk or deputy clerk or upon its mayor or manager.” Conn.Gen.Stat. § 52-57(b)(5). To serve the State DRS, service must be made upon the State. Service “may be made by a proper officer (1) leaving a true and attested copy of the contested matter (here, the Motions) and the notice of contested matter response date required by our Local Bankruptcy Rules, with the Attorney General at the office of the Attorney General in Hartford, or (2) sending a true and attested copy of the contested matter (here, the

Motions) and the notice of contested matter response date required by our Local Bankruptcy Rules, by certified mail, return receipt requested, to the Attorney General at the office of the Attorney General in Hartford.” Conn.Gen.Stat. § 52-64(a); Local Bankruptcy Rule 9014-1. See also Fed.R.Bankr.P. 5003(e) (requiring the Clerk of the Bankruptcy Court to maintain a register of mailing addresses for federal and state governmental units and certain taxing authorities). The Motions Here Were Not Adequately Served Here, the Debtor served the Motions on the Respondents by mail to an address for notice found on the Respondents’ various proofs of claim or by serving appearing

counsel for a Respondent, instead of following the more demanding due process requirements for contested matters identified in Fed.R.Bankr.P. 7004. The Small Business Administration was mailed a copy of ECF No. 40, but it was not addressed to the head of the agency and neither the local United States Attorney’s Office nor the United States Attorney General in Washington, D.C. were served. ECF No. 40, p.8.

While the City Tax Collector was mailed a copy of ECF No. 40, the entity identified in the caption of the Motion was “City of Milford,” not the tax collector, and the document was mailed to the “City Attorney’s Office” which is insufficient under Conn.Gen.Stat. § 52- 57(b)(5). ECF No. 40, pp. 1, 8. The State of Connecticut Department of Revenue Service was mailed a copy of ECF No. 39, to the attention of an Assistant Attorney General who has appeared in the case. ECF No. 39, p.8. However, service addressed to the State DRS’s appearing counsel in the bankruptcy case is not sufficient to comply with the specific service requirements for a contested matter stated in Fed.R.Bankr.P. 7004.

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Ledy J. Madero v. State of Connecticut Department of Revenue Services and Roberta Napoliano, Chapter 13 Trustee; Ledy J. Madero v. US Small Business Administration; City of Milford; Viora Inc. aka Sinclair; and Roberta Napoliano, Chapter 13 Trustee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ledy-j-madero-v-state-of-connecticut-department-of-revenue-services-and-ctb-2026.