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MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 2 Trans ID: LCV2023496982
TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC.
MARC A. SPOSATO, ESQ. (218482017)
186 North Avenue, East
Cranford, NJ 07016
Phone: 908-709-1700
Fax: 908-272-4477
Email: ms@tbwdlaw.com
Attorneys for Defendants, Township of Clark, et al.
SUPERIOR COURT OF NEW JERSEY
THE ESTATE OF MAHA W. QALAWI by LAW DIVISION: MIDDLESEX COUNTY
her ADMINISTRATOR AD
PROSEQUENDUM MADIN BAWWAB
DOCKET NO.: MID-L-6457-22
Plaintiff(s),
VS. CIVIL ACTION
HEATHER SHAW; ESTATE OF JEROME NOTICE OF MOTION
SHAW; CLARK COMMONS; CLARK
TO TRANSFER VENUE
TOWNSHP; COUNTY OF UNION; CLARK
FIRE DEPARTMENT; CLARK POLICE
DEPARTMENT; PATRICK DELOME;
JOHN DOES (1-100) (fictious names) and
A.B.C. COMPANIES (1-100) (fictious entities)
Defendants.
TO: Via eCourts
The Hon. J. Michael A. Toto, A.J.S.C.
Middlesex County Courthouse
56 Paterson Street,
New Brunswick, 08903-0964
Ralph G. Cretella, I.V., Esq.
Garces, Grabler & LeBrocq, P.C.
235 Livingston Avenue
New Brunswick, NJ 08901
PLEASE TAKE NOTICE that on March 3, 2023, at 9:00 a.m. or as soon thereafter as
counsel may be heard, the above Defendants, the Township of Clark, Clark Police Department,
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MID-L-6457-22
Clark Police Officer Patrick Delome, and Clark Fire Department, through its attorneys, the law
firm of Triarsi, Betancourt, Wukovits & Dugan, LLC., shall move before the Hon. Michael A.
Toto, A.J.S.C. at the Middlesex County Courthouse, for an Order transferring the venue of the
above captioned matter to the Union County Superior Court, Law Division.
PLEASE TAKE FURTHER NOTICE that oral argument is only requested if said motion
is opposed.
PLEASE TAKE FURTHER NOTICE that a proposed form of order is attached.
PLEASE TAKE FURTHER NOTICE that, pursuant to R. 1:6-2(c), no pre-trial
conference, arbitration, or trial dates have been fixed.
TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC
________________________________________________
MARC A. SPOSATO, ESQ.
Attorneys for Defendants, Township of Clark, et al.
Dated: February 9, 2023
MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 2 Trans ID: LCV2023496982
TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC.
MARC A. SPOSATO, ESQ. (218482017)
186 North Avenue, East
Cranford, NJ 07016
Phone: 908-709-1700
Fax: 908-272-4477
Email: ms@tbwdlaw.com
Attorneys for Defendants, Township of Clark, et al.
SUPERIOR COURT OF NEW JERSEY
THE ESTATE OF MAHA W. QALWAI by LAW DIVISION: MIDDLESEX COUNTY
her ADMINISTRATOR AD
PROSEQUENDUM MADIN BAWWAB
DOCKET NO.: MID-L-6457-22
Plaintiff(s),
VS. CIVIL ACTION
HEATHER SHAW; ESTATE OF JEROME
SHAW; CLARK COMMONS; CLARK
ORDER
TOWNSHP; COUNTY OF UNION; CLARK
FIRE DEPARTMENT; CLARK POLICE
DEPARTMENT; PATRICK DELOME;
JOHN DOES (1-100) (fictious names) and
A.B.C. COMPANIES (1-100) (fictious entities)
Defendants.
THIS MATTER having been presented to the Court upon application of Defendants the
Township of Clark, Clark Police Department and Clark Fire Department, through their attorneys,
the law firm of Triarsi, Betancourt, Wukovits & Dugan, LLC., Marc A. Sposato, Esq., appearing,
for an Order transferring the venue of this matter to the Union County Superior Court, Law
Division, and Ralph G. Cretella, Esq., counsel for Plaintiff, having appeared; and the Court having
considered the matter and for good cause shown;
IT IS on this _________ day of ____________________ 2023;
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ORDERED that the above captioned matter is hereby transferred to the Union County
Superior Court, Law Division; and it is further
ORDERED that copy of this Order must be served upon all parties within __________
days of the date herein.
___________________________________
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RAFAEL J. BETANCOURT* CENTENNIAL PLAZA
STEVEN F. WUKOVITS† A LIMITED LIABILITY COMPANY 186 NORTH AVENUE, EAST
MARK P. DUGAN** SINCE 1969 CRANFORD, N.J. 07016
RICHARD D. HUXFORD†† www.tbwdlaw.com
_________ Telephone: (908) 709-1700
Facsimile: (908) 272-4477
Writer’s Email: ms@tbwdlaw.com
MARC A. SPOSATO◊
_________ _________
JOSEPH J. TRIARSI JACOB L. TRIARSI
OF COUNSEL OF COUNSEL
(1934-1987)
_________
__________
*NY & PR BARS
†CERTIFIED BY THE SUPREME COURT OF NJ ALFONSO L. PISANO
AS A CRIMINAL TRIAL ATTORNEY
** NY, PA & DC BARS & R. 1:40 MEDIATOR OF COUNSEL
†† CERTIFIED BY THE SUPREME COURT OF NJ (1960-2005)
AS A CERTIFIED MUNICIPAL COURT ATTORNEY
◊NY BAR
February 9, 2023
Via eCourts
The Hon. Michael A. Toto, A.J.S.C.
Middlesex County Courthouse
56 Paterson Street
New Brunswick, 08903-0964
Re: The Estate of Maha W. Qalawi v. Township of Clark, et al.
Docket No.: MID-L-6457-22
Dear Judge Toto:
Please be advised that this law firm represents the Township of Clark, Clark Police
Department, Clark Fire Department and Clark Police Officer Patrick Delome with regard to the
above referenced matter. Please accept this letter brief in lieu of a more formal memorandum of
law in support of the Defendants’ Motion to Transfer Venue.
STATEMENT OF FACTS AND PROCEDURAL HISTORY
The Plaintiff, The Estate of Maha Qalawi, filed its Complaint on or about December 30,
2022 in the Middlesex County Superior Court, Law Division. (See Exhibit D-1.) The Township
of Clark and its respective entities were served with Plaintiff’s complaint on or about January 23,
2023.
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With regard to the allegations contained in the Plaintiff’s complaint, on February 12, 2022,
Plaintiff/Decedent, Maha W. Qawali, was a pedestrian walking on the crosswalk in the Clark
Commons, located at 1255 Raritan Road, in the Township of Clark, County of Union, when she
was reportedly struck by a vehicle driven by Defendant Heather Shaw. (See Exhibit D-1, Par.
16.) Specifically, Ms. Qawali was ran over and pinned to the bottom of the vehicle’s tire, which
caused her death. The Plaintiff has now alleged that the Clark Defendants “engaged in grossly
negligent and reckless emergency response efforts to the accident, which ultimately led to the
demise of the Plaintiff/Decedent.” (See Exhibit D-1, Par. 21.)
LEGAL ARGUMENT
Pursuant to Rule 4:3–2(a)(2), proper venue for actions “brought by or against municipal
corporations, counties, public agencies or officials” is in the county in which the cause of action
arose. New Jersey Court Rule 4:3-2(a)(2) reads as follows:
“Venue shall be laid by the plaintiff in Superior Court actions as
follows … (2) actions not affecting real property which are
brought by or against municipal corporations, counties, public
agencies or officials, in the county in which the cause of action
arose.” (emphasis added)
Pursuant to R. 4:3-3(a)(1), a change of venue is proper where venue is not laid in
accordance with R. 4:3-2. R. 4:3-3(a)(1). Under Rule 4:3-2(a)(2), venue in Superior Court actions
against municipal public entities – like the Township of Clark – not involving real property, shall
be maintained in the county in which the cause of action arose. See Nugent v. Sagner, 151 N.J.
Super. 189, 199- 200 (App. Div. 1977); Diodato v. Camden City Park Comm’n, 136 N.J. Super.
324, 328 (App. Div. 1975); Fine v. Rutgers, 163 N.J. 464, 465 (2000). Rule 4:3-2(a) speaks in
mandatory terms, creating a presumption through the use of the word “shall.” See Diodato, 136
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N.J. Super. at 327. Likewise, a court may also order a change of venue for the convenience of
parties and witnesses in the interest of justice. R. 4:3-3(a)(3).
“The requirement of R.4:3-2(a)(2) has a sound basis in logic. Often the cause of action in
a case involving a public body or official arises in the county where the governmental unit is
located. Ordinarily the witnesses, documents, public officials and counsel are there. The rule
expresses strong policy considerations not to be lightly disregarded.” Doyley v. Schroeter, 191
N.J. Super. 120 (Law Div. 1983) (citing Diodato v. Camden Cty. Park Comm'n., 136 N.J.Super.
324, 346 A.2d 100 (App.Div.1975)).
Here, the Plaintiff has named the Township of Clark, Clark Police Department, Clark
Police Officer Patrick Delome, and Clark Fire Department as Defendants in the within matter, all
of which are public agencies located in Union County. Moreover, Plaintiff has also named the
County of Union as a Defendant, in addition to Defendant Heather Shaw, who also resides in the
Township of Clark. The Plaintiff is the only individual named in the complaint who resides in
Middlesex County.
As the Plaintiff’s cause of action, i.e., the location of the motor vehicle accident, occurred
in the Township of Clark, County of Union, this matter must be transferred to the Union County
Superior Court, Law Division, pursuant to R. 4:3-2(a)(2). Moreover, most, if not all, witnesses
and relevant documentation, are located in Union County. It is clear that the public interest in
venuing this matter in Union County outweighs any potential prejudice the Plaintiff may incur.
CONCLUSION
Based upon the reasons set forth herein, the Defendants, the Township of Clark, Clark
Police Department, Clark Fire Department, and Clark Police Officer Patrick Delome, respectfully
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MID-L-6457-22
request that this Court transfer this case from Middlesex County to Union County pursuant to R.
4:3-3 and R. 4:3-2.
Respectfully submitted,
TRIARSI BETANCOURT WUKOVITS & DUGAN, LLC
MARC A. SPOSATO
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Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-006457-22
Case Caption: THE ESTATE OF MAHA W . QALAWI VS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
SHAW HEATHER VERBAL THRESHOLD)
Case Initiation Date: 12/30/2022 Document Type: Complaint with Jury Demand
Attorney Name: LAWRENCE A LE BROCQ Jury Demand: YES - 12 JURORS
Firm Name: GARCES GRABLER & LEBROCQ, PC Is this a professional malpractice case? NO
Address: 235 LIVINGSTON AVE Related cases pending: NO
NEW BRUNSWICK NJ 08901 If yes, list docket numbers:
Phone: 7322491300 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : THE ESTATE OF MAHA W. transaction or occurrence)? NO
QALAWI Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): STATE FARM INSURANCE Are sexual abuse claims alleged by: THE ESTATE OF MAHA W.
QALAWI? NO
Are sexual abuse claims alleged by: Madin Bawwab? 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? YES 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)
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12/30/2022 /s/ LAWRENCE A LE BROCQ
Dated Signed
Preview
MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 2 Trans ID: LCV2023496982 TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC. MARC A. SPOSATO, ESQ. (218482017) 186 North Avenue, East Cranford, NJ 07016 Phone: 908-709-1700 Fax: 908-272-4477 Email: ms@tbwdlaw.com Attorneys for Defendants, Township of Clark, et al. SUPERIOR COURT OF NEW JERSEY THE ESTATE OF MAHA W. QALAWI by LAW DIVISION: MIDDLESEX COUNTY her ADMINISTRATOR AD PROSEQUENDUM MADIN BAWWAB DOCKET NO.: MID-L-6457-22 Plaintiff(s), VS. CIVIL ACTION HEATHER SHAW; ESTATE OF JEROME NOTICE OF MOTION SHAW; CLARK COMMONS; CLARK TO TRANSFER VENUE TOWNSHP; COUNTY OF UNION; CLARK FIRE DEPARTMENT; CLARK POLICE DEPARTMENT; PATRICK DELOME; JOHN DOES (1-100) (fictious names) and A.B.C. COMPANIES (1-100) (fictious entities) Defendants. TO: Via eCourts The Hon. J. Michael A. Toto, A.J.S.C. Middlesex County Courthouse 56 Paterson Street, New Brunswick, 08903-0964 Ralph G. Cretella, I.V., Esq. Garces, Grabler & LeBrocq, P.C. 235 Livingston Avenue New Brunswick, NJ 08901 PLEASE TAKE NOTICE that on March 3, 2023, at 9:00 a.m. or as soon thereafter as counsel may be heard, the above Defendants, the Township of Clark, Clark Police Department, MID-L-006457-22 02/09/2023 2:35:52 PM Pg 2 of 2 Trans ID: LCV2023496982 Page 2 MID-L-6457-22 Clark Police Officer Patrick Delome, and Clark Fire Department, through its attorneys, the law firm of Triarsi, Betancourt, Wukovits & Dugan, LLC., shall move before the Hon. Michael A. Toto, A.J.S.C. at the Middlesex County Courthouse, for an Order transferring the venue of the above captioned matter to the Union County Superior Court, Law Division. PLEASE TAKE FURTHER NOTICE that oral argument is only requested if said motion is opposed. PLEASE TAKE FURTHER NOTICE that a proposed form of order is attached. PLEASE TAKE FURTHER NOTICE that, pursuant to R. 1:6-2(c), no pre-trial conference, arbitration, or trial dates have been fixed. TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC ________________________________________________ MARC A. SPOSATO, ESQ. Attorneys for Defendants, Township of Clark, et al. Dated: February 9, 2023 MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 2 Trans ID: LCV2023496982 TRIARSI, BETANCOURT, WUKOVITS & DUGAN, LLC. MARC A. SPOSATO, ESQ. (218482017) 186 North Avenue, East Cranford, NJ 07016 Phone: 908-709-1700 Fax: 908-272-4477 Email: ms@tbwdlaw.com Attorneys for Defendants, Township of Clark, et al. SUPERIOR COURT OF NEW JERSEY THE ESTATE OF MAHA W. QALWAI by LAW DIVISION: MIDDLESEX COUNTY her ADMINISTRATOR AD PROSEQUENDUM MADIN BAWWAB DOCKET NO.: MID-L-6457-22 Plaintiff(s), VS. CIVIL ACTION HEATHER SHAW; ESTATE OF JEROME SHAW; CLARK COMMONS; CLARK ORDER TOWNSHP; COUNTY OF UNION; CLARK FIRE DEPARTMENT; CLARK POLICE DEPARTMENT; PATRICK DELOME; JOHN DOES (1-100) (fictious names) and A.B.C. COMPANIES (1-100) (fictious entities) Defendants. THIS MATTER having been presented to the Court upon application of Defendants the Township of Clark, Clark Police Department and Clark Fire Department, through their attorneys, the law firm of Triarsi, Betancourt, Wukovits & Dugan, LLC., Marc A. Sposato, Esq., appearing, for an Order transferring the venue of this matter to the Union County Superior Court, Law Division, and Ralph G. Cretella, Esq., counsel for Plaintiff, having appeared; and the Court having considered the matter and for good cause shown; IT IS on this _________ day of ____________________ 2023; MID-L-006457-22 02/09/2023 2:35:52 PM Pg 2 of 2 Trans ID: LCV2023496982 ORDERED that the above captioned matter is hereby transferred to the Union County Superior Court, Law Division; and it is further ORDERED that copy of this Order must be served upon all parties within __________ days of the date herein. ___________________________________ MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 4 Trans ID: LCV2023496982 RAFAEL J. BETANCOURT* CENTENNIAL PLAZA STEVEN F. WUKOVITS† A LIMITED LIABILITY COMPANY 186 NORTH AVENUE, EAST MARK P. DUGAN** SINCE 1969 CRANFORD, N.J. 07016 RICHARD D. HUXFORD†† www.tbwdlaw.com _________ Telephone: (908) 709-1700 Facsimile: (908) 272-4477 Writer’s Email: ms@tbwdlaw.com MARC A. SPOSATO◊ _________ _________ JOSEPH J. TRIARSI JACOB L. TRIARSI OF COUNSEL OF COUNSEL (1934-1987) _________ __________ *NY & PR BARS †CERTIFIED BY THE SUPREME COURT OF NJ ALFONSO L. PISANO AS A CRIMINAL TRIAL ATTORNEY ** NY, PA & DC BARS & R. 1:40 MEDIATOR OF COUNSEL †† CERTIFIED BY THE SUPREME COURT OF NJ (1960-2005) AS A CERTIFIED MUNICIPAL COURT ATTORNEY ◊NY BAR February 9, 2023 Via eCourts The Hon. Michael A. Toto, A.J.S.C. Middlesex County Courthouse 56 Paterson Street New Brunswick, 08903-0964 Re: The Estate of Maha W. Qalawi v. Township of Clark, et al. Docket No.: MID-L-6457-22 Dear Judge Toto: Please be advised that this law firm represents the Township of Clark, Clark Police Department, Clark Fire Department and Clark Police Officer Patrick Delome with regard to the above referenced matter. Please accept this letter brief in lieu of a more formal memorandum of law in support of the Defendants’ Motion to Transfer Venue. STATEMENT OF FACTS AND PROCEDURAL HISTORY The Plaintiff, The Estate of Maha Qalawi, filed its Complaint on or about December 30, 2022 in the Middlesex County Superior Court, Law Division. (See Exhibit D-1.) The Township of Clark and its respective entities were served with Plaintiff’s complaint on or about January 23, 2023. MID-L-006457-22 02/09/2023 2:35:52 PM Pg 2 of 4 Trans ID: LCV2023496982 Page 2 MID-L-6457-22 With regard to the allegations contained in the Plaintiff’s complaint, on February 12, 2022, Plaintiff/Decedent, Maha W. Qawali, was a pedestrian walking on the crosswalk in the Clark Commons, located at 1255 Raritan Road, in the Township of Clark, County of Union, when she was reportedly struck by a vehicle driven by Defendant Heather Shaw. (See Exhibit D-1, Par. 16.) Specifically, Ms. Qawali was ran over and pinned to the bottom of the vehicle’s tire, which caused her death. The Plaintiff has now alleged that the Clark Defendants “engaged in grossly negligent and reckless emergency response efforts to the accident, which ultimately led to the demise of the Plaintiff/Decedent.” (See Exhibit D-1, Par. 21.) LEGAL ARGUMENT Pursuant to Rule 4:3–2(a)(2), proper venue for actions “brought by or against municipal corporations, counties, public agencies or officials” is in the county in which the cause of action arose. New Jersey Court Rule 4:3-2(a)(2) reads as follows: “Venue shall be laid by the plaintiff in Superior Court actions as follows … (2) actions not affecting real property which are brought by or against municipal corporations, counties, public agencies or officials, in the county in which the cause of action arose.” (emphasis added) Pursuant to R. 4:3-3(a)(1), a change of venue is proper where venue is not laid in accordance with R. 4:3-2. R. 4:3-3(a)(1). Under Rule 4:3-2(a)(2), venue in Superior Court actions against municipal public entities – like the Township of Clark – not involving real property, shall be maintained in the county in which the cause of action arose. See Nugent v. Sagner, 151 N.J. Super. 189, 199- 200 (App. Div. 1977); Diodato v. Camden City Park Comm’n, 136 N.J. Super. 324, 328 (App. Div. 1975); Fine v. Rutgers, 163 N.J. 464, 465 (2000). Rule 4:3-2(a) speaks in mandatory terms, creating a presumption through the use of the word “shall.” See Diodato, 136 MID-L-006457-22 02/09/2023 2:35:52 PM Pg 3 of 4 Trans ID: LCV2023496982 Page 3 MID-L-6457-22 N.J. Super. at 327. Likewise, a court may also order a change of venue for the convenience of parties and witnesses in the interest of justice. R. 4:3-3(a)(3). “The requirement of R.4:3-2(a)(2) has a sound basis in logic. Often the cause of action in a case involving a public body or official arises in the county where the governmental unit is located. Ordinarily the witnesses, documents, public officials and counsel are there. The rule expresses strong policy considerations not to be lightly disregarded.” Doyley v. Schroeter, 191 N.J. Super. 120 (Law Div. 1983) (citing Diodato v. Camden Cty. Park Comm'n., 136 N.J.Super. 324, 346 A.2d 100 (App.Div.1975)). Here, the Plaintiff has named the Township of Clark, Clark Police Department, Clark Police Officer Patrick Delome, and Clark Fire Department as Defendants in the within matter, all of which are public agencies located in Union County. Moreover, Plaintiff has also named the County of Union as a Defendant, in addition to Defendant Heather Shaw, who also resides in the Township of Clark. The Plaintiff is the only individual named in the complaint who resides in Middlesex County. As the Plaintiff’s cause of action, i.e., the location of the motor vehicle accident, occurred in the Township of Clark, County of Union, this matter must be transferred to the Union County Superior Court, Law Division, pursuant to R. 4:3-2(a)(2). Moreover, most, if not all, witnesses and relevant documentation, are located in Union County. It is clear that the public interest in venuing this matter in Union County outweighs any potential prejudice the Plaintiff may incur. CONCLUSION Based upon the reasons set forth herein, the Defendants, the Township of Clark, Clark Police Department, Clark Fire Department, and Clark Police Officer Patrick Delome, respectfully MID-L-006457-22 02/09/2023 2:35:52 PM Pg 4 of 4 Trans ID: LCV2023496982 Page 4 MID-L-6457-22 request that this Court transfer this case from Middlesex County to Union County pursuant to R. 4:3-3 and R. 4:3-2. Respectfully submitted, TRIARSI BETANCOURT WUKOVITS & DUGAN, LLC MARC A. SPOSATO MID-L-006457-22 02/09/2023 2:35:52 PM Pg 1 of 25 Trans ID: LCV2023496982 EXHIBIT D-1 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg12of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg23of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg34of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg45of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg56of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg67of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg78of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg89of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 02/09/2023 12/30/2022 2:35:52 2:09:22 PM Pg 10 9 ofof21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg10 11of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg11 12of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg12 13of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg13 14of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg14 15of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg15 16of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg16 17of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg17 18of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg18 19of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg19 20of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg20 21of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 MID-L-006457-22 12/30/2022 02/09/20232:09:22 2:35:52PM PM Pg Pg21 22of of21 25 Trans TransID: ID:LCV20224468907 LCV2023496982 MID-L-006457-22 02/09/2023 2:35:52 PM Pg 23 of 25 Trans ID: LCV2023496982 MID-L-006457-22 02/09/2023 MID-L-006457-22 MID-L-006457-22 12/30/20222:35:52 12/30/2022 2:09:22PM 2:09:22 PM Pg PM Pg24 1 of of225 Trans TransID: Trans LCV20224468907 ID:ID: LCV20224468907 LCV2023496982 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-006457-22 Case Caption: THE ESTATE OF MAHA W . QALAWI VS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- SHAW HEATHER VERBAL THRESHOLD) Case Initiation Date: 12/30/2022 Document Type: Complaint with Jury Demand Attorney Name: LAWRENCE A LE BROCQ Jury Demand: YES - 12 JURORS Firm Name: GARCES GRABLER & LEBROCQ, PC Is this a professional malpractice case? NO Address: 235 LIVINGSTON AVE Related cases pending: NO NEW BRUNSWICK NJ 08901 If yes, list docket numbers: Phone: 7322491300 Do you anticipate adding any parties (arising out of same Name of Party: PLAINTIFF : THE ESTATE OF MAHA W. transaction or occurrence)? NO QALAWI Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): STATE FARM INSURANCE Are sexual abuse claims alleged by: THE ESTATE OF MAHA W. QALAWI? NO Are sexual abuse claims alleged by: Madin Bawwab? 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? YES 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) MID-L-006457-22 02/09/2023 MID-L-006457-22 MID-L-006457-22 12/30/20222:35:52 12/30/2022 2:09:22PM 2:09:22 PM Pg PM Pg25 2 of of225 Trans TransID: Trans LCV20224468907 ID:ID: LCV20224468907 LCV2023496982 12/30/2022 /s/ LAWRENCE A LE BROCQ Dated Signed