Connecticut General Statutes §47a-23(e) does not require that the lease termination date in the notice to quit be subsequent to the date for the tenant to vacate the premises. The plaintiff landlord, 422 Main Street L.P., brought a summary-process action against the defendant, Patricia Robinson. The defendant filed a special defense and argued that when the landlord uses a combined termination notice and notice to quit, the lease termination date, required by federal law and regulations, must be later than the date in the notice to quit for the tenant to vacate the premises. The plaintiff landlord moved to strike the special defense. The court found that the quit date and the lease termination date may be the same date. "[T]he combined termination notice/notice to quit," wrote the court, "is a valid and unequivocal notice to quit in that it complies with Conn. Gen. Stat. §47a-23(e)." The court granted the landlord's motion to strike the tenant's special defense.

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