Preview
ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 1 of 6 Trans ID: LCV20223711245
LAW OFFICE OF
CHARLES A. LITTLE, JR.
Jill Teague, Esquire NJ ID: 028991995
304 Harper Drive, Suite 202
Moorestown, NJ 08057
T: 856-291-7512 / Fax No: 855-202-0107
Attorneys for Defendant(s), Mark Sheffield and Eastern Warehouse Distributors, LLC
MARK MOLINA and RAUL MOLINA, h/w : SUPERIOR COURT OF NEW JERSEY
Plaintiffs : LAW DIVISION – ATLANTIC COUNTY
: DOCKET NO.: ATL-L-2559-22
-vs- :
: CIVIL ACTION
:
MARK SHEFFIELD, EASTERN :
WAREHOUSE DISTRIBUTORS LLC, JOHN : ANSWER TO COMPLAINT,
DOES (1-10) (Fictitious), ABC : DESIGNATION OF TRIAL COUNSEL,
PARTNERSHIPS (1-10) (Fictitious) and XYZ : REQUEST FOR STATEMENT OF
CORPORATIONS (1-10) (Fictitious); j/s/i/a : DAMAGES, DEMAND FOR ANSWERS
Defendants : TO INTERROGATORIES, SEPARATE
: DEFENSES AND JURY TRIAL DEMAND
:
The Defendant(s), Mark Sheffield and Eastern Warehouse Distributors, LLC, by way of
Answer to the Complaint filed herein, says:
FIRST COUNT
1. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents
of this allegation.
2. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of
this allegation.
3. Denied.
4. Denied.
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WHEREFORE, the answering defendant(s) demand judgment against the plaintiff(s)
denying liability to aforementioned incident in any manner whatever and denying plaintiff
entitlement to compensatory damages, interest or costs of suit.
SECOND COUNT
1. The answering defendant(s) repeat each and every answer made to the allegations set forth
in the First Count, incorporating them herein as if set forth more fully at length.
2. Admitted.
3. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of
this allegation.
4. Denied.
5. Denied.
6. Denied.
WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying
liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to
compensatory damages, interest or costs of suit.
THIRD COUNT
1. The answering defendant(s) repeat each and every answer made to the allegations set forth
in the First Count, incorporating them herein as if set forth more fully at length.
2. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of
this allegation.
3. Denied.
4. Denied.
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WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying
liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to
compensatory damages, interest or costs of suit.
FOURTH COUNT
1. The answering defendant(s) repeat each and every answer made to the allegations set forth
in the First Count, incorporating them herein as if set forth more fully at length.
2. The allegations set forth herein are not addressed to the answering defendant(s) and no
answer hereto is required.
3. The allegations set forth herein are not addressed to the answering defendant(s) and no
answer hereto is required.
WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying
liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to
compensatory damages, interest or costs of suit.
SEPARATE DEFENSES
1. The answering Defendant(s) deny the negligence alleged.
2. The answering Defendant(s) breached no duties allegedly owed.
3. The answering Defendant(s) performed each and every duty allegedly owed.
4. Plaintiff's Complaint is barred by virtue of plaintiff’s own negligence.
5. The injuries and damages of which the plaintiff complains, if any, are the result of plaintiff’s
own negligence and the answering Defendant(s) are not liable therefore.
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6. The injuries and damages of which the plaintiff complains, if any, are the result of actions or
persons over whom the answering Defendant(s) exercised no right or power of control and
the answering Defendant(s) are not liable therefore.
7. The injuries and damages of which the plaintiff complains, if any, were caused by third
parties over whom the answering Defendant(s) exercised no right or power of control and
the answering Defendant(s) are not liable therefore.
8. The negligence, if any, on the part of the answering Defendant(s) were not the proximate
cause of the plaintiff's injury.
9. Plaintiff's Complaint is barred by the applicable Statute of Limitations and the answering
Defendant(s) reserve the right to move to dismiss same.
10. The Plaintiff(s) complaint is barred in whole or in part by the provisions of
N.J.S.A. 39:6A-1 et. seq.
11. The Plaintiff(s) complaint is barred in whole or in part by violation of the provisions of
N.J.S.A. 39:4.
12. Answering Defendant(s) hereby reserve the right to move to amend this answer and
include any defenses which may become available through discovery.
13. Service of process upon the answering Defendant(s) was improper and the answering
Defendant(s) reserves the right to move to dismiss Plaintiff(s) complaint.
14. Plaintiff(s) have failed to mitigate damages and any recovery on the part of the
Plaintiff(s) should be reduced accordingly.
DEMAND FOR INTERROGATORY ANSWERS ON PLAINTIFF
Answering Defendant(s) hereby demand that plaintiff provide certified answers to
Form A Interrogatory questions as set forth in Appendix II of the New Jersey Court Rules.
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DEMAND FOR STATEMENT OF DAMAGES
The answering defendants hereby requests that plaintiff shall furnish a written statement
of damages claimed on its behalf within five (5) days of the service of the within pleading
pursuant to R. 4:5-2.
JURY DEMAND
PLEASE TAKE NOTICE that Answering Defendant(s) hereby demand a trial by jury as
to all issues.
DESIGNATION OF TRIAL COUNSEL
PLEASE TAKE NOTICE that pursuant to Rule 4:25-4, Jill Teague, Esq., of the Law
Office of Charles A. Little, Jr., attorney for the defendant(s), Mark Sheffield and Eastern
Warehouse Distributors, LLC is hereby designated as trial counsel in the above litigation.
Dated: October 17, 2022 /s/ Jill Teague
Jill Teague, Esq.
Attorney for Defendant(s)
Mark Sheffield and Eastern Warehouse Distributors, LLC
CERTIFICATION PURSUANT TO RULE 4:5-1
The undersigned hereby certifies in accordance with Rule 4:5-1 that the above action is not
the subject of any action pending in any Court or of a pending arbitration proceeding. At the
present time no other action or arbitration proceeding is contemplated.
Dated: October 17, 2022 /s/ Jill Teague
Jill Teague, Esq.
Attorney for Defendant(s)
Mark Sheffield and Eastern Warehouse Distributors, LLC
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PROOF OF SERVICE
The original of the within Answer with Case Information Sheet has been filed with Clerk,
ATLANTIC County electronically, via e-Courts.
Dated: October 17, 2022
/s/ Jill Teague
Jill Teague, Esq.
Attorney for Defendant(s)
Mark Sheffield and Eastern Warehouse Distributors, LLC
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Civil Case Information Statement
Case Details: ATLANTIC | Civil Part Docket# L-002559-22
Case Caption: MOLINA MARIA VS SHEFFIELD MARK Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
Case Initiation Date: 09/20/2022 VERBAL THRESHOLD)
Attorney Name: JILL LYNN TEAGUE Document Type: Answer W/Jury Demand
Firm Name: CHARLES A LITTLE JR Jury Demand: YES - 6 JURORS
Address: 304 HARPER DR. STE 202 Is this a professional malpractice case? NO
MOORESTOWN NJ 08057 Related cases pending: NO
Phone: 8562917500 If yes, list docket numbers:
Name of Party: DEFENDANT : SHEFFIELD, MARK Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO
(if known): NATIONWIDE INSURANCECO Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: MARIA MOLINA? NO
Are sexual abuse claims alleged by: RAUL MOLINA? 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)
10/20/2022 /s/ JILL LYNN TEAGUE
Dated Signed
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Preview
ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 1 of 6 Trans ID: LCV20223711245 LAW OFFICE OF CHARLES A. LITTLE, JR. Jill Teague, Esquire NJ ID: 028991995 304 Harper Drive, Suite 202 Moorestown, NJ 08057 T: 856-291-7512 / Fax No: 855-202-0107 Attorneys for Defendant(s), Mark Sheffield and Eastern Warehouse Distributors, LLC MARK MOLINA and RAUL MOLINA, h/w : SUPERIOR COURT OF NEW JERSEY Plaintiffs : LAW DIVISION – ATLANTIC COUNTY : DOCKET NO.: ATL-L-2559-22 -vs- : : CIVIL ACTION : MARK SHEFFIELD, EASTERN : WAREHOUSE DISTRIBUTORS LLC, JOHN : ANSWER TO COMPLAINT, DOES (1-10) (Fictitious), ABC : DESIGNATION OF TRIAL COUNSEL, PARTNERSHIPS (1-10) (Fictitious) and XYZ : REQUEST FOR STATEMENT OF CORPORATIONS (1-10) (Fictitious); j/s/i/a : DAMAGES, DEMAND FOR ANSWERS Defendants : TO INTERROGATORIES, SEPARATE : DEFENSES AND JURY TRIAL DEMAND : The Defendant(s), Mark Sheffield and Eastern Warehouse Distributors, LLC, by way of Answer to the Complaint filed herein, says: FIRST COUNT 1. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of this allegation. 2. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of this allegation. 3. Denied. 4. Denied. ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 2 of 6 Trans ID: LCV20223711245 WHEREFORE, the answering defendant(s) demand judgment against the plaintiff(s) denying liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to compensatory damages, interest or costs of suit. SECOND COUNT 1. The answering defendant(s) repeat each and every answer made to the allegations set forth in the First Count, incorporating them herein as if set forth more fully at length. 2. Admitted. 3. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of this allegation. 4. Denied. 5. Denied. 6. Denied. WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to compensatory damages, interest or costs of suit. THIRD COUNT 1. The answering defendant(s) repeat each and every answer made to the allegations set forth in the First Count, incorporating them herein as if set forth more fully at length. 2. Answering defendant(s) leaves the plaintiff(s) to their proofs with regard to the contents of this allegation. 3. Denied. 4. Denied. ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 3 of 6 Trans ID: LCV20223711245 WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to compensatory damages, interest or costs of suit. FOURTH COUNT 1. The answering defendant(s) repeat each and every answer made to the allegations set forth in the First Count, incorporating them herein as if set forth more fully at length. 2. The allegations set forth herein are not addressed to the answering defendant(s) and no answer hereto is required. 3. The allegations set forth herein are not addressed to the answering defendant(s) and no answer hereto is required. WHEREFORE, the answering defendant(s) demand judgment against the plaintiff denying liability to aforementioned incident in any manner whatever and denying plaintiff entitlement to compensatory damages, interest or costs of suit. SEPARATE DEFENSES 1. The answering Defendant(s) deny the negligence alleged. 2. The answering Defendant(s) breached no duties allegedly owed. 3. The answering Defendant(s) performed each and every duty allegedly owed. 4. Plaintiff's Complaint is barred by virtue of plaintiff’s own negligence. 5. The injuries and damages of which the plaintiff complains, if any, are the result of plaintiff’s own negligence and the answering Defendant(s) are not liable therefore. ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 4 of 6 Trans ID: LCV20223711245 6. The injuries and damages of which the plaintiff complains, if any, are the result of actions or persons over whom the answering Defendant(s) exercised no right or power of control and the answering Defendant(s) are not liable therefore. 7. The injuries and damages of which the plaintiff complains, if any, were caused by third parties over whom the answering Defendant(s) exercised no right or power of control and the answering Defendant(s) are not liable therefore. 8. The negligence, if any, on the part of the answering Defendant(s) were not the proximate cause of the plaintiff's injury. 9. Plaintiff's Complaint is barred by the applicable Statute of Limitations and the answering Defendant(s) reserve the right to move to dismiss same. 10. The Plaintiff(s) complaint is barred in whole or in part by the provisions of N.J.S.A. 39:6A-1 et. seq. 11. The Plaintiff(s) complaint is barred in whole or in part by violation of the provisions of N.J.S.A. 39:4. 12. Answering Defendant(s) hereby reserve the right to move to amend this answer and include any defenses which may become available through discovery. 13. Service of process upon the answering Defendant(s) was improper and the answering Defendant(s) reserves the right to move to dismiss Plaintiff(s) complaint. 14. Plaintiff(s) have failed to mitigate damages and any recovery on the part of the Plaintiff(s) should be reduced accordingly. DEMAND FOR INTERROGATORY ANSWERS ON PLAINTIFF Answering Defendant(s) hereby demand that plaintiff provide certified answers to Form A Interrogatory questions as set forth in Appendix II of the New Jersey Court Rules. ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 5 of 6 Trans ID: LCV20223711245 DEMAND FOR STATEMENT OF DAMAGES The answering defendants hereby requests that plaintiff shall furnish a written statement of damages claimed on its behalf within five (5) days of the service of the within pleading pursuant to R. 4:5-2. JURY DEMAND PLEASE TAKE NOTICE that Answering Defendant(s) hereby demand a trial by jury as to all issues. DESIGNATION OF TRIAL COUNSEL PLEASE TAKE NOTICE that pursuant to Rule 4:25-4, Jill Teague, Esq., of the Law Office of Charles A. Little, Jr., attorney for the defendant(s), Mark Sheffield and Eastern Warehouse Distributors, LLC is hereby designated as trial counsel in the above litigation. Dated: October 17, 2022 /s/ Jill Teague Jill Teague, Esq. Attorney for Defendant(s) Mark Sheffield and Eastern Warehouse Distributors, LLC CERTIFICATION PURSUANT TO RULE 4:5-1 The undersigned hereby certifies in accordance with Rule 4:5-1 that the above action is not the subject of any action pending in any Court or of a pending arbitration proceeding. At the present time no other action or arbitration proceeding is contemplated. Dated: October 17, 2022 /s/ Jill Teague Jill Teague, Esq. Attorney for Defendant(s) Mark Sheffield and Eastern Warehouse Distributors, LLC ATL-L-002559-22 10/20/2022 3:39:56 PM Pg 6 of 6 Trans ID: LCV20223711245 PROOF OF SERVICE The original of the within Answer with Case Information Sheet has been filed with Clerk, ATLANTIC County electronically, via e-Courts. Dated: October 17, 2022 /s/ Jill Teague Jill Teague, Esq. Attorney for Defendant(s) Mark Sheffield and Eastern Warehouse Distributors, LLC ATL-L-002559-22 10/20/2022 ATL-L-002559-22 10/20/20223:39:56 3:39:51PM PM Pg 1 of 2 Trans TransID: ID:LCV20223711245 LCV20223711245 Civil Case Information Statement Case Details: ATLANTIC | Civil Part Docket# L-002559-22 Case Caption: MOLINA MARIA VS SHEFFIELD MARK Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- Case Initiation Date: 09/20/2022 VERBAL THRESHOLD) Attorney Name: JILL LYNN TEAGUE Document Type: Answer W/Jury Demand Firm Name: CHARLES A LITTLE JR Jury Demand: YES - 6 JURORS Address: 304 HARPER DR. STE 202 Is this a professional malpractice case? NO MOORESTOWN NJ 08057 Related cases pending: NO Phone: 8562917500 If yes, list docket numbers: Name of Party: DEFENDANT : SHEFFIELD, MARK Do you anticipate adding any parties (arising out of same Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO (if known): NATIONWIDE INSURANCECO Does this case involve claims related to COVID-19? NO Are sexual abuse claims alleged by: MARIA MOLINA? NO Are sexual abuse claims alleged by: RAUL MOLINA? 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) 10/20/2022 /s/ JILL LYNN TEAGUE Dated Signed ATL-L-002559-22 10/20/2022 ATL-L-002559-22 10/20/20223:39:56 3:39:51PM PM Pg 2 of 2 Trans TransID: ID:LCV20223711245 LCV20223711245