Preview
ATL-L-002620-22 09/23/2022 5:25:37 PM Pglof4 Trans ID: LCV20223431667
Nancy A. Valentino, Esquire
Attorney ID No. 011801997
Law Office of Nancy A. Valentino
600 N. Third Street
Hammonton, NJ 08037
Phone: (609) 432-3929
Fax: (609) 561-8145
Attorney for Plaintiff
FREDERICK CARTY SUPERIOR COURT OF NEW JERSEY
ATLANTIC COUNTY
LAW DIVISION
Plaintiff,
DOCKET NO. ATL-L-
Vv.
CIVIL ACTION
CATHERINE N. BIEL, T & L Transportation,
Inc., John Does 1-5 and ABC Corporations 1-
5 COMPLAINT
Defendants,
Frederick Carty, by way of Complaint against Defendants,
hereby states:
PARTIES
1. Plaintiff is a resident of the Town of Hammonton,
Atlantic County, New Jersey.
2. Defendant, Catherine N. Biel, is a resident of Audub
on, Camden County, New Jersey.
3. Defendant T & L Transportation, Inc. is a corporation author
ized to do business in the
State of New Jersey with a principal place of business at
42 Lakeview Dr., Gibbsboro,
Camden County, New Jersey.
FACTS
4. On or about September 30, 2020, Plaintiff was involv
ed in a motor vehicle accident with
Defendant Catherine N. Biel in Monroe Township, New
Jersey.
ATL-L-002620-22 09/23/2022 5:25:37 PM Pg2of4 Trans ID: LCV20223431667
5. Atall times relevant hereto, Defendant Catherine N. Biel
was the operator of a motor
vehicle traveling East on US Route 322 in Monroe Township,
New Jersey.
6. Atall times relevant hereto, Defendant T & L Transportation,
Inc., was the owner of the
motor vehicle operated by Defendant Catherine N. Biel.
7. Plaintiff, while exercising due caution, was driving his motor vehicle
on Piney Hollow
Road in Monroe Township, New Jersey. The defendant, while operat
ing her motor vehicle,
negligently, recklessly and/or carelessly, violently struck the plainti
ff's vehicle causing him
severe pain and suffering and permanent bodily injury.
8. Asa result of defendant violently striking the plaintiff due to defendant’s neglige
nt,
careless and/or reckless operation of her motor vehicle, plaintiff has
suffered, and will
continue to suffer damages, both economic and non-economic
, which are permanent.
9. Plaintiff has suffered, and continues to suffer, severe pain and sufferi
ng for which
Defendant is liable.
10. Plaintiff has also incurred, and will continue to incur, medical
and other expenses as a
direct result of Defendant’s negligence.
COUNTE
SS ONE ~ EESL
NEGLIGEN
IGENCE
CE
11. Plaintiff repeats and realleges paragraph’s 1 through 10 as if
same were set forth herein
at length.
12. Defendant is liable to Plaintiff for negligence which caused Plainti
ff to suffer severe
injuries, resulting in pain and suffering, medical and other expenses.
WHEREFORE, Plaintiff seeks judgment as follows:
a. Judgment in favor of the Plaintiff and against Defendant:
b Compensatory Damages;
ATL-L-002620-22 09/23/2022 5:25:37 PM Pg3o0f4 Trans ID: LCV20223431667
Punitive Damages;
Pre-Judgment and Post-Judgment interest;
Attorney fees and costs of suit;
Any other such relief as the Court deems equitable and just.
LAW OFFICE OF NANCY A. VALENTINO
By U
NANGY SVALENTINO, ESQUIRE
Dated: September 23, 2022 Attorney for the Plaintiff
gc ERTIFICATION PURSUANT TO 4:5- 1
Thereby certify that to the best of my information, knowledge and belief that the
matter in
controversy is not the subject of any other action pending in any court or of a pending
arbitration
proceeding, that no other action or arbitration proceeding is contemplated, and that
I am not aware
of any other person who should be joined in this matter.
LAW OFFICE OF 3ANCY A. VALENTINO
By:
Npficy A. Valentino, Esquire
ttorney for Plaintiff
Dated: September 23, 2022
D ESIGNATION OF TRIAL COUNSEL PURSUANT TO 4:25- 4
Nancy A. Valentino, Esquire is hereby designated as trial counsel in this matter.
LAW OFFICE OF NANCY A. VALENTINO
By:
Naficy A” Valentino, Esquire
Attorney for Plaintiff
ATL-L-002620-22 09/23/2022 5:25:37 PM Pg4of4 Trans ID: LCV20223431667
DEMAND FOR TRIAL BY JURY PURSUANT TO RULE 4:35-1
Plaintiff hereby demands a jury trial on all issues and claims for which trial by jury is
permitted.
LAW OFFICE OF NANCY A, VALENTINO
nL Ranc¥f A. Valentino, Esquire
Attorney for Plaintiff
Dated: September 23, 2022
ATL-L-002620-22 09/23/2022 5:25:37 PM Pglofl Trans ID: LCV20223431667
Civil Case Information Statement
Case Details: ATLANTIC | Civil Part Docket# L-002620-22
Case Caption: CARTY FREDERICK VS BIEL CATHERINE Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
Case Initiation Date: 09/23/2022 THRESHOLD)
Attorney Name: NANCY ANN VALENTINO. Document Type: Complaint with Jury Demand
Firm Name: NANCY A. VALENTINO Jury Demand: YES - 6 JURORS
Address: 600 N THIRD ST Is this a professional malpractice case? NO
HAMMONTON NJ 08037 Related cases pending: NO
Phone: 6094323929 If yes, list docket numbers:
Name of Party: PLAINTIFF : Carty, Frederick Do you anticipate adding any parties (arising out of same
Name of Defendant's Primary Insurance Company transaction or occurrence)? NO
(if known): None Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: Frederick Carty? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:
Will an interpreter be needed? NO
If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
| certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
09/23/2022 /s/ NANCY ANN VALENTINO
Dated Signed
Preview
ATL-L-002620-22 09/23/2022 5:25:37 PM Pglof4 Trans ID: LCV20223431667 Nancy A. Valentino, Esquire Attorney ID No. 011801997 Law Office of Nancy A. Valentino 600 N. Third Street Hammonton, NJ 08037 Phone: (609) 432-3929 Fax: (609) 561-8145 Attorney for Plaintiff FREDERICK CARTY SUPERIOR COURT OF NEW JERSEY ATLANTIC COUNTY LAW DIVISION Plaintiff, DOCKET NO. ATL-L- Vv. CIVIL ACTION CATHERINE N. BIEL, T & L Transportation, Inc., John Does 1-5 and ABC Corporations 1- 5 COMPLAINT Defendants, Frederick Carty, by way of Complaint against Defendants, hereby states: PARTIES 1. Plaintiff is a resident of the Town of Hammonton, Atlantic County, New Jersey. 2. Defendant, Catherine N. Biel, is a resident of Audub on, Camden County, New Jersey. 3. Defendant T & L Transportation, Inc. is a corporation author ized to do business in the State of New Jersey with a principal place of business at 42 Lakeview Dr., Gibbsboro, Camden County, New Jersey. FACTS 4. On or about September 30, 2020, Plaintiff was involv ed in a motor vehicle accident with Defendant Catherine N. Biel in Monroe Township, New Jersey. ATL-L-002620-22 09/23/2022 5:25:37 PM Pg2of4 Trans ID: LCV20223431667 5. Atall times relevant hereto, Defendant Catherine N. Biel was the operator of a motor vehicle traveling East on US Route 322 in Monroe Township, New Jersey. 6. Atall times relevant hereto, Defendant T & L Transportation, Inc., was the owner of the motor vehicle operated by Defendant Catherine N. Biel. 7. Plaintiff, while exercising due caution, was driving his motor vehicle on Piney Hollow Road in Monroe Township, New Jersey. The defendant, while operat ing her motor vehicle, negligently, recklessly and/or carelessly, violently struck the plainti ff's vehicle causing him severe pain and suffering and permanent bodily injury. 8. Asa result of defendant violently striking the plaintiff due to defendant’s neglige nt, careless and/or reckless operation of her motor vehicle, plaintiff has suffered, and will continue to suffer damages, both economic and non-economic , which are permanent. 9. Plaintiff has suffered, and continues to suffer, severe pain and sufferi ng for which Defendant is liable. 10. Plaintiff has also incurred, and will continue to incur, medical and other expenses as a direct result of Defendant’s negligence. COUNTE SS ONE ~ EESL NEGLIGEN IGENCE CE 11. Plaintiff repeats and realleges paragraph’s 1 through 10 as if same were set forth herein at length. 12. Defendant is liable to Plaintiff for negligence which caused Plainti ff to suffer severe injuries, resulting in pain and suffering, medical and other expenses. WHEREFORE, Plaintiff seeks judgment as follows: a. Judgment in favor of the Plaintiff and against Defendant: b Compensatory Damages; ATL-L-002620-22 09/23/2022 5:25:37 PM Pg3o0f4 Trans ID: LCV20223431667 Punitive Damages; Pre-Judgment and Post-Judgment interest; Attorney fees and costs of suit; Any other such relief as the Court deems equitable and just. LAW OFFICE OF NANCY A. VALENTINO By U NANGY SVALENTINO, ESQUIRE Dated: September 23, 2022 Attorney for the Plaintiff gc ERTIFICATION PURSUANT TO 4:5- 1 Thereby certify that to the best of my information, knowledge and belief that the matter in controversy is not the subject of any other action pending in any court or of a pending arbitration proceeding, that no other action or arbitration proceeding is contemplated, and that I am not aware of any other person who should be joined in this matter. LAW OFFICE OF 3ANCY A. VALENTINO By: Npficy A. Valentino, Esquire ttorney for Plaintiff Dated: September 23, 2022 D ESIGNATION OF TRIAL COUNSEL PURSUANT TO 4:25- 4 Nancy A. Valentino, Esquire is hereby designated as trial counsel in this matter. LAW OFFICE OF NANCY A. VALENTINO By: Naficy A” Valentino, Esquire Attorney for Plaintiff ATL-L-002620-22 09/23/2022 5:25:37 PM Pg4of4 Trans ID: LCV20223431667 DEMAND FOR TRIAL BY JURY PURSUANT TO RULE 4:35-1 Plaintiff hereby demands a jury trial on all issues and claims for which trial by jury is permitted. LAW OFFICE OF NANCY A, VALENTINO nL Ranc¥f A. Valentino, Esquire Attorney for Plaintiff Dated: September 23, 2022 ATL-L-002620-22 09/23/2022 5:25:37 PM Pglofl Trans ID: LCV20223431667 Civil Case Information Statement Case Details: ATLANTIC | Civil Part Docket# L-002620-22 Case Caption: CARTY FREDERICK VS BIEL CATHERINE Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL Case Initiation Date: 09/23/2022 THRESHOLD) Attorney Name: NANCY ANN VALENTINO. Document Type: Complaint with Jury Demand Firm Name: NANCY A. VALENTINO Jury Demand: YES - 6 JURORS Address: 600 N THIRD ST Is this a professional malpractice case? NO HAMMONTON NJ 08037 Related cases pending: NO Phone: 6094323929 If yes, list docket numbers: Name of Party: PLAINTIFF : Carty, Frederick Do you anticipate adding any parties (arising out of same Name of Defendant's Primary Insurance Company transaction or occurrence)? NO (if known): None Does this case involve claims related to COVID-19? NO Are sexual abuse claims alleged by: Frederick Carty? NO THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION Do parties have a current, past, or recurrent relationship? NO If yes, is that relationship: Does the statute governing this case provide for payment of fees by the losing party? NO Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition: Do you or your client need any disability accommodations? NO If yes, please identify the requested accommodation: Will an interpreter be needed? NO If yes, for what language: Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO | certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b) 09/23/2022 /s/ NANCY ANN VALENTINO Dated Signed