Jenzack Partners, LLC v. Stoneridge Associates, LLC, 334 Conn. 374

Stoneridge Associates obtained a $1,650,000 construction loan from Sovereign Bank; several parties (including Jennifer Tine) executed guarantees and, to secure her limited guarantee, Tine and her then-husband granted a mortgage on their Cromwell residence.
The Stoneridge note was modified over time; Tine executed reaffirmations and a limited (nonrecourse as to her) guaranty securing the modified note.
Sovereign assigned the Stoneridge note and the Tine mortgage to Jenzack; an allonge endorsed the note to Jenzack but did not expressly mention assignment of Tine’s guaranty.
After Stoneridge defaulted, Jenzack sued to foreclose the Tine mortgage and to collect on the guaranty; at trial Jenzack introduced exhibit 22, its computation of the amount owed, which incorporated an initial starting balance supplied by Sovereign when the note was sold.
The trial court entered strict foreclosure for Jenzack; the Appellate Court affirmed standing but reversed as to admissibility of the initial entry in exhibit 22 under Conn. Gen. Stat. §52-180 (business records exception), remanding for a new trial.
The Connecticut Supreme Court granted certification on two issues: (1) whether assignment of the note gave Jenzack standing to enforce Tine’s guaranty/mortgage; and (2) whether the initial entry provided by Sovereign and incorporated into Jenzack’s records was admissible under the business-records exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether assignee of note has standing to enforce guaranty/mortgage when guaranty not expressly assigned	Assignment of the note transferred rights to collect on guarantees; guaranty language shows it "inures to successors and assigns" so Jenzack is a holder entitled to enforce	Allonge did not explicitly assign the guaranty; without express assignment, assignee lacks standing to enforce guaranty/mortgage	Held for plaintiff: guaranty expressly inured to future holders; assignment of the note operated as assignment of the guaranty, giving Jenzack standing
Whether initial entry (starting balance) provided by seller (Sovereign) and integrated into buyer's records is admissible under §52-180	Exhibit 22 is Jenzack’s business record; Sovereign had a business duty to report the balance in the sale transaction, and Jenzack incorporated that figure into its own records—thus admissible	The starting figure is hearsay because it was received (not made) by Jenzack and lacks foundation/testimony proving accuracy	Held for plaintiff: admissible. When a business incorporates third‑party data provided pursuant to a business duty into its own records, those integrated records may be admitted; challenges go to weight, not admissibility

Citibank, N.A. v. Lindland, 310 Conn. 147 (Conn.) (standing is right to invoke court jurisdiction)
Pond View, LLC v. Planning & Zoning Commission, 288 Conn. 143 (Conn.) (standard of plenary review for legal questions)
New England Savings Bank v. Bedford Realty Corp., 246 Conn. 594 (Conn.) (Bedford II) (§52-180 construed liberally; business records need not be prepared by offering organization)
New England Savings Bank v. Bedford Realty Corp., 238 Conn. 745 (Conn.) (Bedford I) (limits on witness testimony to prove amount owed absent foundation)
River Dock & Pile, Inc. v. O & G Industries, Inc., 219 Conn. 787 (Conn.) (third‑party information can be part of entrant’s business record when provider had duty to transmit it)
U.S. Bank Trust, N.A. v. Jones, 925 F.3d 534 (1st Cir.) (integrated loan‑servicer records admissible where predecessor servicers had business duty to report; challenges affect weight)