Preview
MID-L-000375-23 01/23/2023 10:06:52 AM Pglof3 Trans ID: LCV2023333522
EDWARD P. SHAMY, JR., ESQ.
ar #001251982
300 ROUTE 27
ORTH BRUNSWICK, NEW JERSEY 08902
732) 821-0400
ftitorney for Plaintiff(s)
1
IRISSA BAILEY, an infant by her guardian t' SUPERIOR COURT OF NEW JERSEY
1
ad litem, IRIS BAILEY, and IRIS BAILEY, 1' LAW DIVISION
individually MIDDLESEX COUNTY
Plaintiff, DOCKET NO.
NALDA CRUZ, TAMIKA BAILEY, CIVIL ACTION
JOHN/JANE DOE 1-10 and/or ABC CORP.
1-10 (fictitious names) COMPLAINT AND JURY DEMAND
Defendants.
Plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS BAILEY, residing a
7 Quincy Circle, Dayton, Middlesex County, NJ, and IRIS BAILEY, individually, residing at 204
ones Drive, Princeton, Mercer County, State of New Jersey, complaining of the defendants do say
FIRST COUNT
1 On or about July 24, 2021 the infant plaintiff, IRISSA BAILEY, was a passenger it}
A certain motor vehicle owned and operated by defendant(s), TAMIKA BAILEY, JOHN/JANE
[DOE 1-5 and/or ABC CORP. 1-5 (fictitious names). Said vehicle was traveling on Forest Drive
Piscataway Township, Middlesex County, New Jersey.
2 At the time and place aforesaid, the defendant, NALDA CRUZ and/or JOHN/JANH
IDOE 6 (fictitious name), was the operator of a motor vehicle owned by the defendant(s), NALDA
(CRUZ, JOHN/JANE DOE 7-10 and/or ABC CORP. 6-10 (fictitious names). Defendant!
ALDA CRUZ and/or JOHN/JANE DOE 6 (fictitious name), operated said vehicle as agent
servant and/or employee of the defendant(s), NALDA CRUZ JOHN/JANE DOE 6-10 and/or ABC
ICORP. 6-10 (fictitious names).
MID-L-000375-23 01/23/2023 10:06:52 AM Pg2of3 Trans ID: LCV2023333522
3 The defendant(s), NALDA CRUZ, JOHN/JANE DOE 6-10 and/or ABC CORP. 6+
0 (fictitious name) were negligent in the operation and ownership of his/her vehicle, as a resul
f which a collision occurred.
4 As a direct and proximate result of the negligence of the defendants herein, thd
infant plaintiff, IRISSA BAILEY, sustained severe personal injuries, has and will suffer pain, hag
ind will incur medical expenses, and has and will be unable to engage in her ususal activities, alte
fer damage, and has sustained bodily injury of such nature and degree to satisfy the threshold pre
‘equisites of N.J.S.A.39:6A-8 et seq.
WHEREFORE, plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS
BAILEY, and IRIS BAILEY, individually, demand judgment against the defendants, NALDA
CRUZ, JOHN/JANE DOE 6-10 and/or ABC CORP.6-10 (fictitious names), for damages, interest.
and costs of suit.
SECOND COUNT
1 Plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS BAILEY, and
RIS BAILEY, individually, repeats and realleges each and every allegation of the First Count a
f same were more fully set forth at length herein.
2 On or about July 24, 2021 the infant plaintiff, IRISSA BAILEY, was a passenge!
na certain motor vehicle owned and operated by defendant(s), TAMIKA BAILEY, JOHN/JANE
DOE 1-5 and/or ABC CORP. 1-5 (fictitious names). Said vehicle was traveling on Forest Drive
Piscataway Township, Middlesex County, New Jersey.
3 Defendant, TAMIKA BAILEY and/or JOHN/JANE DOE 1 (fictitious name)
operated said vehicle as agent, servant and/or employee of the defendant(s), TAMIKA BAILEY|
JOHN/JANE DOE 6-10 and/or ABC CORP. 6-10 (fictitious names).
4 The defendant(s), TAMIKA BAILEY, JOHN/JANE DOE 1-5 and/or ABC CORP|
1-5 (fictitious name) were negligent in the operation and ownership of his/her vehicle, as a resul|
f which a collision occurred.
MID-L-000375-23 01/23/2023 10:06:52 AM Pg3of3 Trans ID: LCV2023333522
4 As a direct and proximate result of the negligence of the defendants herein, the
Infant plaintiff, IRISSA BAILEY, sustained severe personal injuries, has and will suffer pain, hag
nd will incur medical expenses, and has and will be unable to engage in her ususal activities, alte’
er damage, and has sustained bodily injury of such nature and degree to satisfy the threshold pre:
lequisites of N.J.S.A.39:6A-8 et seq.
WHEREFORE, plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS
AILEY, and IRIS BAILEY, individually, demand judgment against the defendants, TAMIKA)
BAILEY, JOHN/JANE DOE 1-5 and/or ABC CORP. 1-5 (fictitious names), for damages.
nterest, and costs of suit.
DESIGNATION OF TRIAL COUNSEL PURSUANT TO R.4:25-4
Pursuant to R.4:25-4, we do hereby designate Edward P. Shamy, Jr., Esq. as trial counsel
n this matter.
DEMAND FOR TRIAL BY JURY
Please take notice that the plaintiff demands a trial by jury pursuant to R.4:35-1. Please tak
urther notice that the provisions of the New Jersey Automobile Reparation Reform Act have beer]
met.
CERTIFICATION PURSUANT TO R. 4:5-1
Thereby certify that the matter in controversy is not the subject of any other action pending
n any other court or of a pending Arbitration proceeding, and that no other action or Arbitration
proceeding is presently contemplated. I hereby further certify that there are no other parties that ar
presently known who should be joined in this action.
2
ZZ
EDWARD P. oe IR., ESQ.
MID-L-000375-23 01/23/2023 10:06:52 AM Pglof2 Trans ID: LCV2023333522
Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-000375-23
Case Caption: BAILEY IRISSA VS CRUZ NALDA Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
Case Initiation Date: 01/23/2023 THRESHOLD)
Attorney Name: EDWARD P SHAMY JR Document Type: Complaint with Jury Demand
Firm Name: EDWARD P. SHAMY, JR. Jury Demand: YES - 6 JURORS
Address: 2300 ROUTE 27 Is this a professional malpractice case? NO
NORTH BRUNSWICK NJ 08902 Related cases pending: NO
Phone: 7328210400 If yes, list docket numbers:
Name of Party: PLAINTIFF : BAILEY, IRISSA 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: IRISSA BAILEY? NO
Are sexual abuse claims alleged by: IRIS BAILEY? NO
Are sexual abuse claims alleged by: IRIS BAILEY? 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)
MID-L-000375-23 01/23/2023 10:06:52 AM Pg2of2 Trans ID: LCV2023333522
01/23/2023 /s/ EDWARD P SHAMY JR
Dated Signed
Preview
MID-L-000375-23 01/23/2023 10:06:52 AM Pglof3 Trans ID: LCV2023333522 EDWARD P. SHAMY, JR., ESQ. ar #001251982 300 ROUTE 27 ORTH BRUNSWICK, NEW JERSEY 08902 732) 821-0400 ftitorney for Plaintiff(s) 1 IRISSA BAILEY, an infant by her guardian t' SUPERIOR COURT OF NEW JERSEY 1 ad litem, IRIS BAILEY, and IRIS BAILEY, 1' LAW DIVISION individually MIDDLESEX COUNTY Plaintiff, DOCKET NO. NALDA CRUZ, TAMIKA BAILEY, CIVIL ACTION JOHN/JANE DOE 1-10 and/or ABC CORP. 1-10 (fictitious names) COMPLAINT AND JURY DEMAND Defendants. Plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS BAILEY, residing a 7 Quincy Circle, Dayton, Middlesex County, NJ, and IRIS BAILEY, individually, residing at 204 ones Drive, Princeton, Mercer County, State of New Jersey, complaining of the defendants do say FIRST COUNT 1 On or about July 24, 2021 the infant plaintiff, IRISSA BAILEY, was a passenger it} A certain motor vehicle owned and operated by defendant(s), TAMIKA BAILEY, JOHN/JANE [DOE 1-5 and/or ABC CORP. 1-5 (fictitious names). Said vehicle was traveling on Forest Drive Piscataway Township, Middlesex County, New Jersey. 2 At the time and place aforesaid, the defendant, NALDA CRUZ and/or JOHN/JANH IDOE 6 (fictitious name), was the operator of a motor vehicle owned by the defendant(s), NALDA (CRUZ, JOHN/JANE DOE 7-10 and/or ABC CORP. 6-10 (fictitious names). Defendant! ALDA CRUZ and/or JOHN/JANE DOE 6 (fictitious name), operated said vehicle as agent servant and/or employee of the defendant(s), NALDA CRUZ JOHN/JANE DOE 6-10 and/or ABC ICORP. 6-10 (fictitious names). MID-L-000375-23 01/23/2023 10:06:52 AM Pg2of3 Trans ID: LCV2023333522 3 The defendant(s), NALDA CRUZ, JOHN/JANE DOE 6-10 and/or ABC CORP. 6+ 0 (fictitious name) were negligent in the operation and ownership of his/her vehicle, as a resul f which a collision occurred. 4 As a direct and proximate result of the negligence of the defendants herein, thd infant plaintiff, IRISSA BAILEY, sustained severe personal injuries, has and will suffer pain, hag ind will incur medical expenses, and has and will be unable to engage in her ususal activities, alte fer damage, and has sustained bodily injury of such nature and degree to satisfy the threshold pre ‘equisites of N.J.S.A.39:6A-8 et seq. WHEREFORE, plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS BAILEY, and IRIS BAILEY, individually, demand judgment against the defendants, NALDA CRUZ, JOHN/JANE DOE 6-10 and/or ABC CORP.6-10 (fictitious names), for damages, interest. and costs of suit. SECOND COUNT 1 Plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS BAILEY, and RIS BAILEY, individually, repeats and realleges each and every allegation of the First Count a f same were more fully set forth at length herein. 2 On or about July 24, 2021 the infant plaintiff, IRISSA BAILEY, was a passenge! na certain motor vehicle owned and operated by defendant(s), TAMIKA BAILEY, JOHN/JANE DOE 1-5 and/or ABC CORP. 1-5 (fictitious names). Said vehicle was traveling on Forest Drive Piscataway Township, Middlesex County, New Jersey. 3 Defendant, TAMIKA BAILEY and/or JOHN/JANE DOE 1 (fictitious name) operated said vehicle as agent, servant and/or employee of the defendant(s), TAMIKA BAILEY| JOHN/JANE DOE 6-10 and/or ABC CORP. 6-10 (fictitious names). 4 The defendant(s), TAMIKA BAILEY, JOHN/JANE DOE 1-5 and/or ABC CORP| 1-5 (fictitious name) were negligent in the operation and ownership of his/her vehicle, as a resul| f which a collision occurred. MID-L-000375-23 01/23/2023 10:06:52 AM Pg3of3 Trans ID: LCV2023333522 4 As a direct and proximate result of the negligence of the defendants herein, the Infant plaintiff, IRISSA BAILEY, sustained severe personal injuries, has and will suffer pain, hag nd will incur medical expenses, and has and will be unable to engage in her ususal activities, alte’ er damage, and has sustained bodily injury of such nature and degree to satisfy the threshold pre: lequisites of N.J.S.A.39:6A-8 et seq. WHEREFORE, plaintiff, IRISSA BAILEY, an infant by her guardian ad litem, IRIS AILEY, and IRIS BAILEY, individually, demand judgment against the defendants, TAMIKA) BAILEY, JOHN/JANE DOE 1-5 and/or ABC CORP. 1-5 (fictitious names), for damages. nterest, and costs of suit. DESIGNATION OF TRIAL COUNSEL PURSUANT TO R.4:25-4 Pursuant to R.4:25-4, we do hereby designate Edward P. Shamy, Jr., Esq. as trial counsel n this matter. DEMAND FOR TRIAL BY JURY Please take notice that the plaintiff demands a trial by jury pursuant to R.4:35-1. Please tak urther notice that the provisions of the New Jersey Automobile Reparation Reform Act have beer] met. CERTIFICATION PURSUANT TO R. 4:5-1 Thereby certify that the matter in controversy is not the subject of any other action pending n any other court or of a pending Arbitration proceeding, and that no other action or Arbitration proceeding is presently contemplated. I hereby further certify that there are no other parties that ar presently known who should be joined in this action. 2 ZZ EDWARD P. oe IR., ESQ. MID-L-000375-23 01/23/2023 10:06:52 AM Pglof2 Trans ID: LCV2023333522 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-000375-23 Case Caption: BAILEY IRISSA VS CRUZ NALDA Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL Case Initiation Date: 01/23/2023 THRESHOLD) Attorney Name: EDWARD P SHAMY JR Document Type: Complaint with Jury Demand Firm Name: EDWARD P. SHAMY, JR. Jury Demand: YES - 6 JURORS Address: 2300 ROUTE 27 Is this a professional malpractice case? NO NORTH BRUNSWICK NJ 08902 Related cases pending: NO Phone: 7328210400 If yes, list docket numbers: Name of Party: PLAINTIFF : BAILEY, IRISSA 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: IRISSA BAILEY? NO Are sexual abuse claims alleged by: IRIS BAILEY? NO Are sexual abuse claims alleged by: IRIS BAILEY? 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) MID-L-000375-23 01/23/2023 10:06:52 AM Pg2of2 Trans ID: LCV2023333522 01/23/2023 /s/ EDWARD P SHAMY JR Dated Signed