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BER-L-005730-22 06/23/2023 5:57:41 PM Pg 1 of 14 Trans ID: LCV20231883712
THOMAS T. KIM, ESQ. (ID #038422012)
KOULIKOURDIS AND ASSOCIATES
Hudson Professional Building
45 Hudson Street
Hackensack, New Jersey 07601
Tel: (201) 489-6644; Fax: (201) 489-3575
e-mail: pkoulkourdis@gmail.com
Attorneys for Defendant Christian Reyes
ESTATE OF MARKO GUBEROVIC BY SUPERIOR COURT OF NEW JERSEY
HIS ADMINSTRATOR AD LAW DIVISION
PROSEQUENDUM NINA PRALL,
BERGEN COUNTY
Plaintiffs,
DOCKET NO.: BER-L-5730-22
v.
Civil Action
BRYAN WOOD, ABC BAR 1-10
ANSWER, SEPARATE DEFENSES,
(Fictitious bar and owners of bar where
CROSS-CLAIM,
Bryan Wood was overserved), JOE
DEMAND FOR STATEMENT OF
BARKEEP 1-10 (Fictitious server of
DAMAGES, JURY DEMAND,
alcohol), SATIN DOLLS, XYZ BAR
DESIGNATION
OWNERS 1-5 (Fictitious Entity owning
OF TRIAL COUNSEL, AND
Satin Dolls); JANE BARTENDER 1-10
CERTIFICATION
(Fictitious server of alcohol at Satin
Dolls); FERO HOTI, ARDIAN HOTI,
JULIO PENA, KEVIN AGUEDELO &
CHRISTIAN REYES, ET AL.,
Defendants.
The Defendant, CHRISTIAN REYES, by way of Answer to the Plaintiff’s
Counterclaims, hereby states as follows:
ANSWER TO COMPLAINT
1. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 1 of the FACTS AS TO ALL COUNTS of the Plaintiff’s
Complaint and leaves the Plaintiff to its proofs.
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2. The Defendant, CHRISTIAN REYES, denies the allegations set forth in
Paragraph 2 of the FACTS AS TO ALL COUNTS of the Plaintiff’s Complaint.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the FACTS AS TO ALL COUNTS of the Plaintiff’s
Complaint and leaves the Plaintiff to its proofs.
FIRST COUNT
1. The Defendant, CHRISTIAN REYES, denies the allegations set forth in
Paragraph 1 of the FIRST COUNT of the Complaint.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the FIRST COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the FIRST COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the FIRST COUNT and leaves the Plaintiff to its proofs.
5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 5 of the FIRST COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
SECOND COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
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2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the SECOND COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the SECOND COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the SECOND COUNT and leaves the Plaintiff to its proofs.
5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 5 of the SECOND COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
THIRD COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the THIRD COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the THIRD COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the THIRD COUNT and leaves the Plaintiff to its proofs.
5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 5 of the THIRD COUNT and leaves the Plaintiff to its proofs.
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WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
FOURTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the FOURTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the FOURTH COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
FIFTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the FIFTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the FIFTH COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the FIFTH COUNT and leaves the Plaintiff to its proofs.
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WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
SIXTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the SIXTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the SIXTH COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the SIXTH COUNT and leaves the Plaintiff to its proofs.
5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 5 of the SIXTH COUNT and leaves the Plaintiff to its proofs.
6. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 6 of the SIXTH COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
SEVENTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
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2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the SEVENTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the SEVENTH COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the SEVENTH COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
EIGHTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 2 of the EIGHTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 3 of the EIGHTH COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 4 of the EIGHTH COUNT and leaves the Plaintiff to its proofs.
5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as
set forth in Paragraph 5 of the EIGHTH COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
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NINTH COUNT
1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding
responses and defenses of the Answer as if set forth at length herein.
2. The Defendant, CHRISTIAN REYES, denies the allegations set forth in
Paragraph 2 of the NINTH COUNT and leaves the Plaintiff to its proofs.
3. The Defendant, CHRISTIAN REYES, denies the allegations set forth in
Paragraph 3 of the NINTH COUNT and leaves the Plaintiff to its proofs.
4. The Defendant, CHRISTIAN REYES, denies the allegations set forth in
Paragraph 4 of the NINTH COUNT and leaves the Plaintiff to its proofs.
WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
KOULIKOURDIS AND ASSOCIATES
Attorneys for Defendant Christian Reyes
BY: /s/ Thomas T. Kim
Dated: June 23, 2023 THOMAS T. KIM, ESQ.
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SEPARATE AFFIRMATIVE DEFENSES
1. The Plaintiff’s Complaint fails to state a cause of action upon which relief can be
granted.
2. The Defendant, CHRISTIAN REYES is guilty of no negligence, no actual fault and
no failure to act.
3. The damages alleged in the Plaintiff’s Complaint are the result of intervening
and/or superseding acts of negligence on the part of persons and/or entitles over whom
the Defendant, CHRISTIAN REYES, had no control nor right of control and for whose
actions these Defendants are not liable.
4. While denying any negligence or intentional conduct with regard to the subject
matter of the Plaintiff’s Complaint, the Defendant, CHRISTIAN REYES, state that
insofar as such negligence or improper intentional conduct is found, their negligence is
not the proximate cause of the injuries alleged by Plaintiffs.
5. The Plaintiff’s claims are barred by the applicable statute of limitations.
6. The Plaintiff’s claims are barred or, at the very least, the damages to which they
are entitled should be reduced by virtue of the doctrine of comparative negligence and the
comparative negligence act.
7. The Plaintiff’s Claims are barred by comparative negligence.
8. The Plaintiff’s Claims are barred or, at the very least, the damages to which they
are entitled, should be reduced by virtue of the Doctrine of Avoidable Consequences.
9. The Defendant, CHRISTIAN REYES, denies that he breached any duty due and
owing to the Plaintiff.
10. The acts or omissions complained of in the Plaintiff’s Complaint were caused by
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and/or are attributable to persons or entities over whom the Defendant, CHRISTIAN
REYES, had no control nor right of control and for whose actions the Defendant,
CHRISTIAN REYES, is not liable.
11. The damages to which the Plaintiff alleges he is entitled to should be reduced by
the virtue of the Doctrine of Mitigation of Damages.
12. The Plaintiff is estopped from asserting its claim(s) for damages against the
Defendant, CHRISTIAN REYES.
13. The Plaintiff’s conduct operates as a waiver of a right to recovery against the
Defendant, CHRISTIAN REYES.
14. Any breach of duty on the part of the Defendant, CHRISTIAN REYES, was not
the proximate cause of any damages sustained by the Plaintiff while Defendants deny any
breach of duty.
15. The accident and damages alleged are due to the negligence of third persons over
whom this defendant exercised no control.
16. Service upon said Defendant was improper.
17. The Defendant, CHRISTIAN REYES, reserves the right to assert additional
defenses and/or supplement, alter, amend and change their Answer upon the revelation of
more definite facts from the various parties to the suit and contemplation of further
discovery and investigation.
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WHEREFORE, the Answering Defendant demands judgment dismissing the
Plaintiff’s complaint, together with interest and costs of suit and any other relief this
court deems just and equitable.
KOULIKOURDIS AND ASSOCIATES
Attorneys for Defendant Christian Reyes
BY: /s/ Thomas T. Kim
Dated: June 23, 2023 THOMAS T. KIM, ESQ.
CROSS-CLAIMS
FIRST COUNT – CONTRIBUTION
1. The Defendant, CHRISTIAN REYES, denies that he is in any way liable to the
Plaintiff under the claims for relief asserted in the Plaintiff’s Complaint. However, if the
Defendant, CHRISTIAN REYES, is held responsible for damages allegedly suffered by
the Plaintiff, he is entitled to contribution from the remaining Defendants BRYAN
WOOD, ABC BAR 1-10 (Fictitious bar and owners of bar where Bryan Wood was
overserved), SATIN DOLLS, JOE BARKEEP 1-10 (Fictitious server of alcohol), FERO
HOTI, ARDIAN HOTI, JULIO PENA, KEVIN AGUEDELO, ALLSTATE
INSURANCE COMPANY (UM and/or UIM Coverage/Purposes), ABC Insurance
Company 1-10 (Names being fictitious companies), and any unnamed future defendants
or third-party defendants in this matter under New Jersey law who are not represented by
the undersigned law firm.
WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment
against the remaining Defendants and any unnamed future Defendants or Third-Party
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Defendants who are not represented by the undersigned law firm, pursuant to the
provisions of the New Jersey Joint Tortfeasors Contribution Act, N.J.S.A. 2A:53A-1 et
seq. and/or N.J. Stat. Ann. §§ 2A:53A-1 to -5, the New Jersey Comparative Negligence
Act, N.J.S.A. 2A:15-1 et seq., N.J.S.A. 2A:155.3, and/or N.J.S.A. 2A:15-5.1 et seq., and
common law.
SECOND COUNT – INDEMNIFICATION
1. The Defendant, CHRISTIAN REYES, denies any and all legal liability and/or
responsibility for the acts alleged against him in the Plaintiff’s Complaint.
2. Should the Defendant, CHRISTIAN REYES, be found liable to the Plaintiff,
which liability is expressly denied, said liability would be merely secondary, passive,
technical, imputed or vicarious and, as a result, any damages (including attorney’s fees
and defense costs) for which the Defendant, CHRISTIAN REYES may be liable are
chargeable to the remaining Defendants BRYAN WOOD, ABC BAR 1-10 (Fictitious bar
and owners of bar where Bryan Wood was overserved), SATIN DOLLS, JOE BARKEEP
1-10 (Fictitious server of alcohol), FERO HOTI, ARDIAN HOTI, JULIO PENA, KEVIN
AGUEDELO, ALLSTATE INSURANCE COMPANY (UM and/or UIM
Coverage/Purposes), ABC Insurance Company 1-10 (Names being fictitious companies),
and any unnamed future defendants or third-party defendants in this matter under New
Jersey law who are not represented by the undersigned law firm.
WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment
against the remaining Defendants and any unnamed future Defendants or Third-Party
Defendants who are not represented by the undersigned law firm, indemnification and/or
contractual indemnification.
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THIRD COUNT – INSURANCE
1. While denying all allegations of liability, proximate cause and damages, at the
time of the subject incident, there were applicable contracts and insurance policies that
were or did provide for insurance coverage for the benefit of the Defendant, CHRISTIAN
REYES, from the co-Defendants and/or the co-Defendants’ insurers. The damages to the
Defendant, CHRISTIAN REYES, if any, were the direct and proximate result of, among
other breaches, the co-defendants’ or the insurer’s denial of insurance or additional
insured coverage, failure to obtain insurance or additional insured coverage, and/or
obtaining incorrect or insufficient insurance or additional insured coverage for any co-
Defendant for their breach of contract and other acts and omissions for all sums and
damages as may be found against and from the Defendant, CHRISTIAN REYES,,
including all costs and attorneys’ fees.
WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment
against the remaining Defendants and any unnamed future Defendants or Third-Party
Defendants who are not represented by the undersigned law firm for all sums for which
the Defendant, CHRISTIAN REYES, may be held liable to Plaintiff on this Third Count
of the Crossclaim
DEFENDANT’S ANSWER TO ANY AND ALL CROSSCLAIMS
The Defendant, CHRISTIAN REYES, denies all allegations contained in any and all
crossclaims and/or counterclaims filed against it, or to be filed against it in this action, by
any and all co-Defendants, third party Defendants, and any future Defendants or named
persons or parties in this matter who are not represented by this law firm; including any
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and all crossclaims and/or counterclaims filed against it for indemnification and/or
contribution including as follows:
1. The Defendant, CHRISTIAN REYES, denies any and all crossclaims for
contribution.
2. The Defendant, CHRISTIAN REYES, denies any and all crossclaims for
indemnification.
3. The Defendant, CHRISTIAN REYES, denies any and all other crossclaims.
DEMAND FOR STATEMENT OF DAMAGES
Pursuant to the provisions of Rule 4:5-2, the plaintiff(s) shall provide, within five
days, a written statement of the damages claimed in this action.
JURY DEMAND
The Defendant herewith demands a trial by jury on all issues so triable.
KOULIKOURDIS AND ASSOCIATES
Attorneys for Defendant Christian Reyes
BY: /s/ Thomas T. Kim
Dated: June 23, 2023 THOMAS T. KIM, ESQ.
DESIGNATION OF TRIAL COUNSEL
Thomas T. Kim, Esq. is hereby designated as the trial counsel for the Defendant.
KOULIKOURDIS AND ASSOCIATES
Attorneys for Defendant Christian Reyes
BY: /s/ Thomas T. Kim
Dated: June 23, 2023 THOMAS T. KIM, ESQ.
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CERTIFICATION PURSUANT TO RULE 4:5-1
I certify pursuant to R. 4:5-1 that to the best of my knowledge the within matter is
not the subject matter of any other action pending in any Court and is not the subject of
any pending arbitration proceeding except that criminal proceedings appear to be pending
against some or all of the other defendants named in this action. I further certify, to the
best of my knowledge, no other action or arbitration proceeding is contemplated
concerning the matter in controversy except as otherwise set forth herein. I further
certify, to the best of my knowledge, no other parties need to be joined in this matter at
this time. Upon further investigation and discovery, this Defendant reserves the right to
file a motion for leave of court to amend its Answer to name specific cross-claim or third-
party defendants as necessary.
CERTIFICATION PURSUANT TO RULE 1:38-7(b)
I 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 N.J. Ct. R. 1:38-7(b).
CERTIFICATION PURSUANT TO RULE 4:6-1(d)
I certify in accordance with N.J. Ct. R. 4:6-1(d), that the within pleading was filed
with the Court and served upon all counsel of record within the time period prescribed by
the Rules of Court. I certify that the foregoing statements made by me are true. I further
certify that if any of the foregoing statements made by me is willfully false, I am subject
to punishment.
KOULIKOURDIS AND ASSOCIATES
Attorneys for Defendant Christian Reyes
BY: /s/ Thomas T. Kim
Dated: June 23, 2023 THOMAS T. KIM, ESQ.
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Civil Case Information Statement
Case Details: BERGEN | Civil Part Docket# L-005730-22
Case Caption: GUBEROVIC MARKO VS WOOD BRYAN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
Case Initiation Date: 10/25/2022 VERBAL THRESHOLD)
Attorney Name: PETER JOHN KOULIKOURDIS Document Type: Answer W/CrossClaim W/Jury Demand
Firm Name: KOULIKOURDIS & ASSOCIATES Jury Demand: YES - 12 JURORS
Address: 45 HUDSON STREET Is this a professional malpractice case? NO
HACKENSACK NJ 07601 Related cases pending: NO
Phone: 2014896644 If yes, list docket numbers:
Name of Party: DEFENDANT : REYES, CHRISTIAN Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? YES
(if known): Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: MARKO GUBEROVIC? NO
Are sexual abuse claims alleged by: NINA PRALL? 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
I 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)
06/23/2023 /s/ PETER JOHN KOULIKOURDIS
Dated Signed
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Preview
BER-L-005730-22 06/23/2023 5:57:41 PM Pg 1 of 14 Trans ID: LCV20231883712 THOMAS T. KIM, ESQ. (ID #038422012) KOULIKOURDIS AND ASSOCIATES Hudson Professional Building 45 Hudson Street Hackensack, New Jersey 07601 Tel: (201) 489-6644; Fax: (201) 489-3575 e-mail: pkoulkourdis@gmail.com Attorneys for Defendant Christian Reyes ESTATE OF MARKO GUBEROVIC BY SUPERIOR COURT OF NEW JERSEY HIS ADMINSTRATOR AD LAW DIVISION PROSEQUENDUM NINA PRALL, BERGEN COUNTY Plaintiffs, DOCKET NO.: BER-L-5730-22 v. Civil Action BRYAN WOOD, ABC BAR 1-10 ANSWER, SEPARATE DEFENSES, (Fictitious bar and owners of bar where CROSS-CLAIM, Bryan Wood was overserved), JOE DEMAND FOR STATEMENT OF BARKEEP 1-10 (Fictitious server of DAMAGES, JURY DEMAND, alcohol), SATIN DOLLS, XYZ BAR DESIGNATION OWNERS 1-5 (Fictitious Entity owning OF TRIAL COUNSEL, AND Satin Dolls); JANE BARTENDER 1-10 CERTIFICATION (Fictitious server of alcohol at Satin Dolls); FERO HOTI, ARDIAN HOTI, JULIO PENA, KEVIN AGUEDELO & CHRISTIAN REYES, ET AL., Defendants. The Defendant, CHRISTIAN REYES, by way of Answer to the Plaintiff’s Counterclaims, hereby states as follows: ANSWER TO COMPLAINT 1. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 1 of the FACTS AS TO ALL COUNTS of the Plaintiff’s Complaint and leaves the Plaintiff to its proofs. 1 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 2 of 14 Trans ID: LCV20231883712 2. The Defendant, CHRISTIAN REYES, denies the allegations set forth in Paragraph 2 of the FACTS AS TO ALL COUNTS of the Plaintiff’s Complaint. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the FACTS AS TO ALL COUNTS of the Plaintiff’s Complaint and leaves the Plaintiff to its proofs. FIRST COUNT 1. The Defendant, CHRISTIAN REYES, denies the allegations set forth in Paragraph 1 of the FIRST COUNT of the Complaint. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the FIRST COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the FIRST COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the FIRST COUNT and leaves the Plaintiff to its proofs. 5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 5 of the FIRST COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. SECOND COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 3 of 14 Trans ID: LCV20231883712 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the SECOND COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the SECOND COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the SECOND COUNT and leaves the Plaintiff to its proofs. 5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 5 of the SECOND COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. THIRD COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the THIRD COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the THIRD COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the THIRD COUNT and leaves the Plaintiff to its proofs. 5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 5 of the THIRD COUNT and leaves the Plaintiff to its proofs. 3 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 4 of 14 Trans ID: LCV20231883712 WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. FOURTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the FOURTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the FOURTH COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. FIFTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the FIFTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the FIFTH COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the FIFTH COUNT and leaves the Plaintiff to its proofs. 4 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 5 of 14 Trans ID: LCV20231883712 WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. SIXTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the SIXTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the SIXTH COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the SIXTH COUNT and leaves the Plaintiff to its proofs. 5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 5 of the SIXTH COUNT and leaves the Plaintiff to its proofs. 6. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 6 of the SIXTH COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. SEVENTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 5 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 6 of 14 Trans ID: LCV20231883712 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the SEVENTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the SEVENTH COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the SEVENTH COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. EIGHTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 2 of the EIGHTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 3 of the EIGHTH COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 4 of the EIGHTH COUNT and leaves the Plaintiff to its proofs. 5. The Defendant, CHRISTIAN REYES, neither admits nor denies the allegations as set forth in Paragraph 5 of the EIGHTH COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. 6 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 7 of 14 Trans ID: LCV20231883712 NINTH COUNT 1. The Defendant, CHRISTIAN REYES, repeats and realleges all of the preceding responses and defenses of the Answer as if set forth at length herein. 2. The Defendant, CHRISTIAN REYES, denies the allegations set forth in Paragraph 2 of the NINTH COUNT and leaves the Plaintiff to its proofs. 3. The Defendant, CHRISTIAN REYES, denies the allegations set forth in Paragraph 3 of the NINTH COUNT and leaves the Plaintiff to its proofs. 4. The Defendant, CHRISTIAN REYES, denies the allegations set forth in Paragraph 4 of the NINTH COUNT and leaves the Plaintiff to its proofs. WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. KOULIKOURDIS AND ASSOCIATES Attorneys for Defendant Christian Reyes BY: /s/ Thomas T. Kim Dated: June 23, 2023 THOMAS T. KIM, ESQ. 7 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 8 of 14 Trans ID: LCV20231883712 SEPARATE AFFIRMATIVE DEFENSES 1. The Plaintiff’s Complaint fails to state a cause of action upon which relief can be granted. 2. The Defendant, CHRISTIAN REYES is guilty of no negligence, no actual fault and no failure to act. 3. The damages alleged in the Plaintiff’s Complaint are the result of intervening and/or superseding acts of negligence on the part of persons and/or entitles over whom the Defendant, CHRISTIAN REYES, had no control nor right of control and for whose actions these Defendants are not liable. 4. While denying any negligence or intentional conduct with regard to the subject matter of the Plaintiff’s Complaint, the Defendant, CHRISTIAN REYES, state that insofar as such negligence or improper intentional conduct is found, their negligence is not the proximate cause of the injuries alleged by Plaintiffs. 5. The Plaintiff’s claims are barred by the applicable statute of limitations. 6. The Plaintiff’s claims are barred or, at the very least, the damages to which they are entitled should be reduced by virtue of the doctrine of comparative negligence and the comparative negligence act. 7. The Plaintiff’s Claims are barred by comparative negligence. 8. The Plaintiff’s Claims are barred or, at the very least, the damages to which they are entitled, should be reduced by virtue of the Doctrine of Avoidable Consequences. 9. The Defendant, CHRISTIAN REYES, denies that he breached any duty due and owing to the Plaintiff. 10. The acts or omissions complained of in the Plaintiff’s Complaint were caused by 8 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 9 of 14 Trans ID: LCV20231883712 and/or are attributable to persons or entities over whom the Defendant, CHRISTIAN REYES, had no control nor right of control and for whose actions the Defendant, CHRISTIAN REYES, is not liable. 11. The damages to which the Plaintiff alleges he is entitled to should be reduced by the virtue of the Doctrine of Mitigation of Damages. 12. The Plaintiff is estopped from asserting its claim(s) for damages against the Defendant, CHRISTIAN REYES. 13. The Plaintiff’s conduct operates as a waiver of a right to recovery against the Defendant, CHRISTIAN REYES. 14. Any breach of duty on the part of the Defendant, CHRISTIAN REYES, was not the proximate cause of any damages sustained by the Plaintiff while Defendants deny any breach of duty. 15. The accident and damages alleged are due to the negligence of third persons over whom this defendant exercised no control. 16. Service upon said Defendant was improper. 17. The Defendant, CHRISTIAN REYES, reserves the right to assert additional defenses and/or supplement, alter, amend and change their Answer upon the revelation of more definite facts from the various parties to the suit and contemplation of further discovery and investigation. 9 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 10 of 14 Trans ID: LCV20231883712 WHEREFORE, the Answering Defendant demands judgment dismissing the Plaintiff’s complaint, together with interest and costs of suit and any other relief this court deems just and equitable. KOULIKOURDIS AND ASSOCIATES Attorneys for Defendant Christian Reyes BY: /s/ Thomas T. Kim Dated: June 23, 2023 THOMAS T. KIM, ESQ. CROSS-CLAIMS FIRST COUNT – CONTRIBUTION 1. The Defendant, CHRISTIAN REYES, denies that he is in any way liable to the Plaintiff under the claims for relief asserted in the Plaintiff’s Complaint. However, if the Defendant, CHRISTIAN REYES, is held responsible for damages allegedly suffered by the Plaintiff, he is entitled to contribution from the remaining Defendants BRYAN WOOD, ABC BAR 1-10 (Fictitious bar and owners of bar where Bryan Wood was overserved), SATIN DOLLS, JOE BARKEEP 1-10 (Fictitious server of alcohol), FERO HOTI, ARDIAN HOTI, JULIO PENA, KEVIN AGUEDELO, ALLSTATE INSURANCE COMPANY (UM and/or UIM Coverage/Purposes), ABC Insurance Company 1-10 (Names being fictitious companies), and any unnamed future defendants or third-party defendants in this matter under New Jersey law who are not represented by the undersigned law firm. WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment against the remaining Defendants and any unnamed future Defendants or Third-Party 10 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 11 of 14 Trans ID: LCV20231883712 Defendants who are not represented by the undersigned law firm, pursuant to the provisions of the New Jersey Joint Tortfeasors Contribution Act, N.J.S.A. 2A:53A-1 et seq. and/or N.J. Stat. Ann. §§ 2A:53A-1 to -5, the New Jersey Comparative Negligence Act, N.J.S.A. 2A:15-1 et seq., N.J.S.A. 2A:155.3, and/or N.J.S.A. 2A:15-5.1 et seq., and common law. SECOND COUNT – INDEMNIFICATION 1. The Defendant, CHRISTIAN REYES, denies any and all legal liability and/or responsibility for the acts alleged against him in the Plaintiff’s Complaint. 2. Should the Defendant, CHRISTIAN REYES, be found liable to the Plaintiff, which liability is expressly denied, said liability would be merely secondary, passive, technical, imputed or vicarious and, as a result, any damages (including attorney’s fees and defense costs) for which the Defendant, CHRISTIAN REYES may be liable are chargeable to the remaining Defendants BRYAN WOOD, ABC BAR 1-10 (Fictitious bar and owners of bar where Bryan Wood was overserved), SATIN DOLLS, JOE BARKEEP 1-10 (Fictitious server of alcohol), FERO HOTI, ARDIAN HOTI, JULIO PENA, KEVIN AGUEDELO, ALLSTATE INSURANCE COMPANY (UM and/or UIM Coverage/Purposes), ABC Insurance Company 1-10 (Names being fictitious companies), and any unnamed future defendants or third-party defendants in this matter under New Jersey law who are not represented by the undersigned law firm. WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment against the remaining Defendants and any unnamed future Defendants or Third-Party Defendants who are not represented by the undersigned law firm, indemnification and/or contractual indemnification. 11 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 12 of 14 Trans ID: LCV20231883712 THIRD COUNT – INSURANCE 1. While denying all allegations of liability, proximate cause and damages, at the time of the subject incident, there were applicable contracts and insurance policies that were or did provide for insurance coverage for the benefit of the Defendant, CHRISTIAN REYES, from the co-Defendants and/or the co-Defendants’ insurers. The damages to the Defendant, CHRISTIAN REYES, if any, were the direct and proximate result of, among other breaches, the co-defendants’ or the insurer’s denial of insurance or additional insured coverage, failure to obtain insurance or additional insured coverage, and/or obtaining incorrect or insufficient insurance or additional insured coverage for any co- Defendant for their breach of contract and other acts and omissions for all sums and damages as may be found against and from the Defendant, CHRISTIAN REYES,, including all costs and attorneys’ fees. WHEREFORE, the Defendant, CHRISTIAN REYES, demands judgment against the remaining Defendants and any unnamed future Defendants or Third-Party Defendants who are not represented by the undersigned law firm for all sums for which the Defendant, CHRISTIAN REYES, may be held liable to Plaintiff on this Third Count of the Crossclaim DEFENDANT’S ANSWER TO ANY AND ALL CROSSCLAIMS The Defendant, CHRISTIAN REYES, denies all allegations contained in any and all crossclaims and/or counterclaims filed against it, or to be filed against it in this action, by any and all co-Defendants, third party Defendants, and any future Defendants or named persons or parties in this matter who are not represented by this law firm; including any 12 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 13 of 14 Trans ID: LCV20231883712 and all crossclaims and/or counterclaims filed against it for indemnification and/or contribution including as follows: 1. The Defendant, CHRISTIAN REYES, denies any and all crossclaims for contribution. 2. The Defendant, CHRISTIAN REYES, denies any and all crossclaims for indemnification. 3. The Defendant, CHRISTIAN REYES, denies any and all other crossclaims. DEMAND FOR STATEMENT OF DAMAGES Pursuant to the provisions of Rule 4:5-2, the plaintiff(s) shall provide, within five days, a written statement of the damages claimed in this action. JURY DEMAND The Defendant herewith demands a trial by jury on all issues so triable. KOULIKOURDIS AND ASSOCIATES Attorneys for Defendant Christian Reyes BY: /s/ Thomas T. Kim Dated: June 23, 2023 THOMAS T. KIM, ESQ. DESIGNATION OF TRIAL COUNSEL Thomas T. Kim, Esq. is hereby designated as the trial counsel for the Defendant. KOULIKOURDIS AND ASSOCIATES Attorneys for Defendant Christian Reyes BY: /s/ Thomas T. Kim Dated: June 23, 2023 THOMAS T. KIM, ESQ. 13 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 14 of 14 Trans ID: LCV20231883712 CERTIFICATION PURSUANT TO RULE 4:5-1 I certify pursuant to R. 4:5-1 that to the best of my knowledge the within matter is not the subject matter of any other action pending in any Court and is not the subject of any pending arbitration proceeding except that criminal proceedings appear to be pending against some or all of the other defendants named in this action. I further certify, to the best of my knowledge, no other action or arbitration proceeding is contemplated concerning the matter in controversy except as otherwise set forth herein. I further certify, to the best of my knowledge, no other parties need to be joined in this matter at this time. Upon further investigation and discovery, this Defendant reserves the right to file a motion for leave of court to amend its Answer to name specific cross-claim or third- party defendants as necessary. CERTIFICATION PURSUANT TO RULE 1:38-7(b) I 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 N.J. Ct. R. 1:38-7(b). CERTIFICATION PURSUANT TO RULE 4:6-1(d) I certify in accordance with N.J. Ct. R. 4:6-1(d), that the within pleading was filed with the Court and served upon all counsel of record within the time period prescribed by the Rules of Court. I certify that the foregoing statements made by me are true. I further certify that if any of the foregoing statements made by me is willfully false, I am subject to punishment. KOULIKOURDIS AND ASSOCIATES Attorneys for Defendant Christian Reyes BY: /s/ Thomas T. Kim Dated: June 23, 2023 THOMAS T. KIM, ESQ. 14 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 1 of 2 Trans ID: LCV20231883712 BER-L-005730-22 06/23/2023 5:57:41 PM Pg 2 of 2 Trans ID: LCV20231883712 BER-L-005730-22 06/23/2023 BER-L-005730-22 06/23/20235:57:41 5:57:13PM PM Pg 1 of 2 Trans TransID: ID:LCV20231883712 LCV20231883712 Civil Case Information Statement Case Details: BERGEN | Civil Part Docket# L-005730-22 Case Caption: GUBEROVIC MARKO VS WOOD BRYAN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- Case Initiation Date: 10/25/2022 VERBAL THRESHOLD) Attorney Name: PETER JOHN KOULIKOURDIS Document Type: Answer W/CrossClaim W/Jury Demand Firm Name: KOULIKOURDIS & ASSOCIATES Jury Demand: YES - 12 JURORS Address: 45 HUDSON STREET Is this a professional malpractice case? NO HACKENSACK NJ 07601 Related cases pending: NO Phone: 2014896644 If yes, list docket numbers: Name of Party: DEFENDANT : REYES, CHRISTIAN Do you anticipate adding any parties (arising out of same Name of Defendant’s Primary Insurance Company transaction or occurrence)? YES (if known): Does this case involve claims related to COVID-19? NO Are sexual abuse claims alleged by: MARKO GUBEROVIC? NO Are sexual abuse claims alleged by: NINA PRALL? 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 I 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) 06/23/2023 /s/ PETER JOHN KOULIKOURDIS Dated Signed BER-L-005730-22 06/23/2023 BER-L-005730-22 06/23/20235:57:41 5:57:13PM PM Pg 2 of 2 Trans TransID: ID:LCV20231883712 LCV20231883712