Preview
MID-L-006460-22 12/30/2022 3:03:36 PM Pglof9 Trans ID: LCV20224469637
Jonathan P. Arnold, Esq. - 1D. No. 020851993
BRAMNICK, RODRIGUEZ, GRABAS,
ARNOLD & MANGAN, LLC
1827 East Second Street
Scotch Plains NJ 07076
Telephone: 908-322-7000
Facsimile: 908-322-6997
Attorneys for Plaintiff
GIOVANNI HERNANDEZ- SUPERIOR COURT OF NEW JERSEY
GOMEZ, LAW DIVISION: MIDDLESEX COUNTY
DOCKET NO.:
Plaintiff,
vs. CIVIL ACTION
RUZIEV LAZIZJON, JOHN COMPLAINT, JURY DEMAND, DEMAND
DOES 1-10 (said names being FOR PRODUCTION OF DOCUMENTS AND
fictitious) and XYZ DEMAND FOR ANSWERS TO
CORPORATIONS 1-10 (said INTERROGATORIES
names being fictitious,
Defendants.
Plaintiff, GIOVANNI HERNANDEZ-GOMEZ, residing at 1600 Kenyon Avenue,
in the Borough of South Plainfield, County of Middlesex and State of New Jersey, by
way of complaint against Defendants, RUZIEV LAZIZJON, JOHN DOES 1-10 (said
names being fictitious) and XYZ CORPORATIONS 1-10 (said names being fictitious)
say:
FIRST COUNT
1 On or about November 30, 2021, plaintiff, GIOVANNI HERNANDEZ-
GOMEZ, was a passenger in a motor vehicle traveling southbound on Somerset Street, at
or near the intersection with Interhaven Avenue, in the Borough of North Plainfield,
County of Somerset and State of New Jersey.
MID-L-006460-22 12/30/2022 3:03:36 PM Pg2of9 Trans ID: LCV20224469637
2 At the above-mentioned time and place, Defendant, RUZIEV
LAZIZJON, was the owner and operator of a motor vehicle then traveling eastbound on
Interhaven Avenue, at or near the intersection with Somerset Street, in the Borough of
North Plainfield, County of Somerset and State of New Jersey.
3 At the above-mentioned time and place, Defendant did so negligently
own, operate, maintain and/or control his motor vehicles so as to cause his motor vehicle
to collide with another vehicle propelling that vehicle into the vehicle being driven by
plaintiff.
4 As a direct and proximate result of the negligence of the Defendant as
aforesaid, Plaintiff has suffered and will suffer much pain in mind and body, has incurred
and will in the future incur expenses for medical care and treatment, has suffered and will
in the future suffer economic loss, was unable and will in the future be unable to attend to
his usual and customary activities and was caused to suffer permanent injury.
5 Plaintiff has obtained the requisite certification from his treating physician
pursuant to Title 39. A copy of same is attached hereto as Exhibit A.
WHEREFORE, Plaintiff, GIOVANNI HERNANDEZ-GOMEZ, demands
judgment against the Defendant, RUZIEV LAZIZJON for damages together with
interest, counsel fees and costs of suit.
SECOND COUNT
1 Plaintiff repeats and reiterates the allegations contained in the First Count
of the Complaint as if set forth more fully at length herein.
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2 Defendants, JOHN DOES 1-10 (names unknown) and XYZ CORP. 1-10
(names unknown), negligently owned, operated, maintained and/or controlled their motor
vehicles so as aforesaid.
3 As a direct and proximate result of the negligence of the Defendants as
aforesaid, Plaintiff has suffered and will in the future suffer much pain in mind and body,
has incurred and will in the future incur expenses for medical care and treatment, has
suffered and will in the future suffer economic loss, was unable and will in the future be
unable to attend to his/her usual customary activities and was caused to suffer permanent
injury.
4 Plaintiff reserves the right to amend the Complaint to join these
potentially culpable parties if discovery should reveal that said parties are in any way
responsible for the injuries sustained by Plaintiff.
WHEREFORE, Plaintiff, GIOVANNI HERNANDEZ-GARCIA, demands
judgment against the Defendants, RUZIEV LAZIZJON, JOHN DOES 1-10 (names
unknown) and/or XYZ CORP. 1-10 (names unknown) for damages together with interest. 2
counsel fees and costs of suit.
DESIGNATION OF TRIAL COUNSEL
Jonathan P. Arnold, Esq., is hereby designated as trial counsel pursuant to Court
Rule 4:5-1.
JURY DEMAND
Plaintiff hereby demands trial by jury as to all issues so triable.
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Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS,
ARNOLD & MANGAN, LLC
Attorneys for Plaintiff
/s/Jonathan P. Arnold
JONATHAN P. ARNOLD, ESQ.
DEMAND FOR INSURANCE INFORMATION
Plaintiff hereby demands that Defendants set forth the name of any insurance
carrier providing coverage for Plaintiff’s injuries, the policy number and the extent of
liability limits.
Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS,
ARNOLD & MANGAN, LLC
Attorneys for Plaintiff
/s/Jonathan P. Arnold
JONATHAN P. ARNOLD, ESQ.
DEMAND FOR PRODUCTION OF DOCUMENTS
PLEASE TAKE NOTICE that pursuant to Rule 4:18-1, Plaintiff hereby
demands that the Defendants produce the following documentation within thirty (30)
days as prescribed by the Rule of Court. Additionally, please be advised that the
following requests are ongoing and continuing in nature and the Defendants are therefore
required to continuously update their responses thereto as new information or
documentation comes into evidence.
1 The amounts of any and all insurance coverage covering the Defendants
including but not limited to primary insurance policies, secondary insurance policies
and/or umbrella insurance policies. For each policy of insurance, supply a copy of the
declaration page therefrom.
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2 Copies of any and all documentation or reports, including but not limited
to police reports, accident reports and/or incident reports concerning the happening of the
incident in question or any subsequent investigation of same.
3 Copies or duplications of any and all photographs, motion pictures,
videotapes, films, drawings, diagrams, sketches or other reproductions, descriptions or
accounts concerning the individuals involved in the incident in question, the property
damage sustained, the accident scene, or anything else relevant to the incident in
question.
4 Copies of any and all signed or unsigned statements, documents,
communications, and/or transmissions, whether in writing, made orally or otherwise
recorded by any mechanical or electronic means, made by any party to this action, any
witness, or any other individual, business, corporation, investigative authority or other
entity concerning anything relevant to the incident in question.
5 Copies of any and all documentation, including but not limited to any
contracts between the owner of the property or product involved in the incident in
question and any of the parties involved in this matter.
6 Copies of any and all documentation, including but not limited to safety
manuals, statutes, rules, regulations, books and/or industry standards which refer to,
reflect or otherwise relate to the incident in question or nay potential defense to the action
in question.
7
Copies of any and all discovery received from any other parties to the
action in question.
MID-L-006460-22 12/30/2022 3:03:36 PM Pg6of9 Trans ID: LCV20224469637
8 Copies of any and all reports on the plaintiffs received by the defendants,
or any other party to this suit, from either the Central Index Bureau (C.L.B.) or from any
other source.
9 Copies of any and all information and/or documentation concerning the
plaintiff in this matter whether it concerns any medical condition or treatment which took
place before, during or after the time of the incident in question.
10. Copies of any and all records of any type subpoenaed by the Defendants
or received from any other source concerning the Plaintiff or the incident in question.
1. Any and all videotapes or moving pictures made of Plaintiff and/or the
subject matter of this accident.
12. Please be advised that the Plaintiff hereby objects to the taking of any
photographs, x-rays or other reproductions concerning the Plaintiff or the Plaintiff's
injuries at the time of defense examination.
13. The entire file maintained by experts whom plaintiff intends to call at trial,
including but not limited to any notes or draft reports, billing statements, x-ray films
and/or other studies.
14, Set forth the name, publisher, date of publication and page reference of
each test, article standard, manual, policy, procedure, directive book or writing of any
kind which your experts relied upon in any way in formulating their opinion in this
matter.
15. A copy of any and all statements provided by defendant concerning this
accident. This includes copies of any and all statements, whether verbal, written or
otherwise, provided to defendant’s insurance company or any adjuster acting on behalf of
MID-L-006460-22 12/30/2022 3:03:36 PM Pg7of9 Trans ID: LCV20224469637
that insurance company, or to any other party. This request is made pursuant to Pfender
v. Torres. , 336 N.J. Super. 379 (App. Div. 2001).
16. A copy of defendant’s cell phone records from the date of the accident,
defendant’s cell phone number and cell phone service provider as of the date of this
accident.
DEMAND FOR ANSWERS TO INTERROGATORIES
Plaintiff hereby demands that the Defendants answer Form C and C(1)
Interrogatories within the time prescribed by the Court Rules.
CERTIFICATION
Pursuant to R. 4:15-1, I hereby certify that the matter in controversy is not the
subject of any other pending or contemplated action or arbitration proceeding. This party
is not aware of any other parties who should be joined in this action at this time. 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).
Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS,
ARNOLD & MANGAN, LLC
Attorneys for Plaintiff
/s/ Jonathan P. Arnold
JONATHAN P. ARNOLD, ESQ.
PHYSICIAN’S CERTIFICATION
A Physician’s Certification complying with N.J.S.A. 39:6A-8a is attached to this
Complaint.
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EXHIBIT “A”
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CERTIFICATION PURSUANT TO N.J,S.A, 39:64-8a OF THE
AUTOMOBILE INSURANCE COST REDUCTION ACT OF 1998
1 Tam a licensed physician as defined by NLLS.A, 45:9-5.1,
2. Iam a treating physician to the plaintiff, Giovanni Hernandez-Gomez, for
injuries sustained on November 30, 2021.
3 All of the opinions set forth herein are within a reasonable degree of medical
probability.
4. As a result of the November 30, 2021 accident, Giovanni Hernandez
Gomez sustained the following injuries:
. Disc bulge at C3-4, C5-6 and C6-7
- Disc bulge at L3-4
~ Disc herniations at L4-5
5 This certification is based on objective clinical evidence including, but not
limited to:
MRI of the Cervical Spine
MRI of the Lumbar Spine
Physical examination.
6 Any testing referred to above is not experimental in nature nor are the results
of such tests dependent entirely on subjective patient response.
7 Based on my professional expertise and objective clinical evidence
including my clinical findings and/or the resultsof objective medical tests, it is my
opinion within a reasonable degree of medical probability that Giovanni Hernandez-
Gomez has sustained a permanent injury in that Giovanni Hernandez-Gomez has/have
not healed to function normally and will not heal to function normally with further
medical treatment.
8 I certify under penalty of perjury that the above conclusions are true to the
best of my knowledge and belief. I am aware that if the foregoing statements made by me
are willfully false, I am subject to punishment.
Dated:
Wafrr
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Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-006460-22
Case Caption: HERNANDEZ-GOMEZ GIOVANNI VS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
HERNANDEZ-GOMEZ GIOV THRESHOLD)
Case Initiation Date: 12/30/2022 Document Type: Complaint with Jury Demand
Attorney Name: JONATHAN PETER ARNOLD Jury Demand: YES - 6 JURORS
Firm Name: BRAMNICK RODRIGUEZ GRABAS ARNOLD & Is this a professional malpractice case? NO
MANGAN LLC Related cases pending: NO
Address: 1827 E SECOND ST If yes, list docket numbers:
SCOTCH PLAINS NJ 07076 Do you anticipate adding any parties (arising out of same
Phone: 9083227000 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Hernandez-Gomez, Giovanni Does this case involve claims related to COVID-19? NO
Name of Defendant's Primary Insurance Company
(if known): Geico Are sexual abuse claims alleged by: Giovanni Hernandez-Gomez?
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)
12/30/2022 /!s/ JONATHAN PETER ARNOLD
Dated Signed
MID-L-006460-22 12/30/2022 3:03:36 PM Pg2of2 Trans ID: LCV20224469637
Preview
MID-L-006460-22 12/30/2022 3:03:36 PM Pglof9 Trans ID: LCV20224469637 Jonathan P. Arnold, Esq. - 1D. No. 020851993 BRAMNICK, RODRIGUEZ, GRABAS, ARNOLD & MANGAN, LLC 1827 East Second Street Scotch Plains NJ 07076 Telephone: 908-322-7000 Facsimile: 908-322-6997 Attorneys for Plaintiff GIOVANNI HERNANDEZ- SUPERIOR COURT OF NEW JERSEY GOMEZ, LAW DIVISION: MIDDLESEX COUNTY DOCKET NO.: Plaintiff, vs. CIVIL ACTION RUZIEV LAZIZJON, JOHN COMPLAINT, JURY DEMAND, DEMAND DOES 1-10 (said names being FOR PRODUCTION OF DOCUMENTS AND fictitious) and XYZ DEMAND FOR ANSWERS TO CORPORATIONS 1-10 (said INTERROGATORIES names being fictitious, Defendants. Plaintiff, GIOVANNI HERNANDEZ-GOMEZ, residing at 1600 Kenyon Avenue, in the Borough of South Plainfield, County of Middlesex and State of New Jersey, by way of complaint against Defendants, RUZIEV LAZIZJON, JOHN DOES 1-10 (said names being fictitious) and XYZ CORPORATIONS 1-10 (said names being fictitious) say: FIRST COUNT 1 On or about November 30, 2021, plaintiff, GIOVANNI HERNANDEZ- GOMEZ, was a passenger in a motor vehicle traveling southbound on Somerset Street, at or near the intersection with Interhaven Avenue, in the Borough of North Plainfield, County of Somerset and State of New Jersey. MID-L-006460-22 12/30/2022 3:03:36 PM Pg2of9 Trans ID: LCV20224469637 2 At the above-mentioned time and place, Defendant, RUZIEV LAZIZJON, was the owner and operator of a motor vehicle then traveling eastbound on Interhaven Avenue, at or near the intersection with Somerset Street, in the Borough of North Plainfield, County of Somerset and State of New Jersey. 3 At the above-mentioned time and place, Defendant did so negligently own, operate, maintain and/or control his motor vehicles so as to cause his motor vehicle to collide with another vehicle propelling that vehicle into the vehicle being driven by plaintiff. 4 As a direct and proximate result of the negligence of the Defendant as aforesaid, Plaintiff has suffered and will suffer much pain in mind and body, has incurred and will in the future incur expenses for medical care and treatment, has suffered and will in the future suffer economic loss, was unable and will in the future be unable to attend to his usual and customary activities and was caused to suffer permanent injury. 5 Plaintiff has obtained the requisite certification from his treating physician pursuant to Title 39. A copy of same is attached hereto as Exhibit A. WHEREFORE, Plaintiff, GIOVANNI HERNANDEZ-GOMEZ, demands judgment against the Defendant, RUZIEV LAZIZJON for damages together with interest, counsel fees and costs of suit. SECOND COUNT 1 Plaintiff repeats and reiterates the allegations contained in the First Count of the Complaint as if set forth more fully at length herein. MID-L-006460-22 12/30/2022 3:03:36 PM Pg3of9 Trans ID: LCV20224469637 2 Defendants, JOHN DOES 1-10 (names unknown) and XYZ CORP. 1-10 (names unknown), negligently owned, operated, maintained and/or controlled their motor vehicles so as aforesaid. 3 As a direct and proximate result of the negligence of the Defendants as aforesaid, Plaintiff has suffered and will in the future suffer much pain in mind and body, has incurred and will in the future incur expenses for medical care and treatment, has suffered and will in the future suffer economic loss, was unable and will in the future be unable to attend to his/her usual customary activities and was caused to suffer permanent injury. 4 Plaintiff reserves the right to amend the Complaint to join these potentially culpable parties if discovery should reveal that said parties are in any way responsible for the injuries sustained by Plaintiff. WHEREFORE, Plaintiff, GIOVANNI HERNANDEZ-GARCIA, demands judgment against the Defendants, RUZIEV LAZIZJON, JOHN DOES 1-10 (names unknown) and/or XYZ CORP. 1-10 (names unknown) for damages together with interest. 2 counsel fees and costs of suit. DESIGNATION OF TRIAL COUNSEL Jonathan P. Arnold, Esq., is hereby designated as trial counsel pursuant to Court Rule 4:5-1. JURY DEMAND Plaintiff hereby demands trial by jury as to all issues so triable. MID-L-006460-22 12/30/2022 3:03:36 PM Pg4of9 Trans ID: LCV20224469637 Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS, ARNOLD & MANGAN, LLC Attorneys for Plaintiff /s/Jonathan P. Arnold JONATHAN P. ARNOLD, ESQ. DEMAND FOR INSURANCE INFORMATION Plaintiff hereby demands that Defendants set forth the name of any insurance carrier providing coverage for Plaintiff’s injuries, the policy number and the extent of liability limits. Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS, ARNOLD & MANGAN, LLC Attorneys for Plaintiff /s/Jonathan P. Arnold JONATHAN P. ARNOLD, ESQ. DEMAND FOR PRODUCTION OF DOCUMENTS PLEASE TAKE NOTICE that pursuant to Rule 4:18-1, Plaintiff hereby demands that the Defendants produce the following documentation within thirty (30) days as prescribed by the Rule of Court. Additionally, please be advised that the following requests are ongoing and continuing in nature and the Defendants are therefore required to continuously update their responses thereto as new information or documentation comes into evidence. 1 The amounts of any and all insurance coverage covering the Defendants including but not limited to primary insurance policies, secondary insurance policies and/or umbrella insurance policies. For each policy of insurance, supply a copy of the declaration page therefrom. MID-L-006460-22 12/30/2022 3:03:36 PM Pg5of9 Trans ID: LCV20224469637 2 Copies of any and all documentation or reports, including but not limited to police reports, accident reports and/or incident reports concerning the happening of the incident in question or any subsequent investigation of same. 3 Copies or duplications of any and all photographs, motion pictures, videotapes, films, drawings, diagrams, sketches or other reproductions, descriptions or accounts concerning the individuals involved in the incident in question, the property damage sustained, the accident scene, or anything else relevant to the incident in question. 4 Copies of any and all signed or unsigned statements, documents, communications, and/or transmissions, whether in writing, made orally or otherwise recorded by any mechanical or electronic means, made by any party to this action, any witness, or any other individual, business, corporation, investigative authority or other entity concerning anything relevant to the incident in question. 5 Copies of any and all documentation, including but not limited to any contracts between the owner of the property or product involved in the incident in question and any of the parties involved in this matter. 6 Copies of any and all documentation, including but not limited to safety manuals, statutes, rules, regulations, books and/or industry standards which refer to, reflect or otherwise relate to the incident in question or nay potential defense to the action in question. 7 Copies of any and all discovery received from any other parties to the action in question. MID-L-006460-22 12/30/2022 3:03:36 PM Pg6of9 Trans ID: LCV20224469637 8 Copies of any and all reports on the plaintiffs received by the defendants, or any other party to this suit, from either the Central Index Bureau (C.L.B.) or from any other source. 9 Copies of any and all information and/or documentation concerning the plaintiff in this matter whether it concerns any medical condition or treatment which took place before, during or after the time of the incident in question. 10. Copies of any and all records of any type subpoenaed by the Defendants or received from any other source concerning the Plaintiff or the incident in question. 1. Any and all videotapes or moving pictures made of Plaintiff and/or the subject matter of this accident. 12. Please be advised that the Plaintiff hereby objects to the taking of any photographs, x-rays or other reproductions concerning the Plaintiff or the Plaintiff's injuries at the time of defense examination. 13. The entire file maintained by experts whom plaintiff intends to call at trial, including but not limited to any notes or draft reports, billing statements, x-ray films and/or other studies. 14, Set forth the name, publisher, date of publication and page reference of each test, article standard, manual, policy, procedure, directive book or writing of any kind which your experts relied upon in any way in formulating their opinion in this matter. 15. A copy of any and all statements provided by defendant concerning this accident. This includes copies of any and all statements, whether verbal, written or otherwise, provided to defendant’s insurance company or any adjuster acting on behalf of MID-L-006460-22 12/30/2022 3:03:36 PM Pg7of9 Trans ID: LCV20224469637 that insurance company, or to any other party. This request is made pursuant to Pfender v. Torres. , 336 N.J. Super. 379 (App. Div. 2001). 16. A copy of defendant’s cell phone records from the date of the accident, defendant’s cell phone number and cell phone service provider as of the date of this accident. DEMAND FOR ANSWERS TO INTERROGATORIES Plaintiff hereby demands that the Defendants answer Form C and C(1) Interrogatories within the time prescribed by the Court Rules. CERTIFICATION Pursuant to R. 4:15-1, I hereby certify that the matter in controversy is not the subject of any other pending or contemplated action or arbitration proceeding. This party is not aware of any other parties who should be joined in this action at this time. 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). Dated: December 30, 2022 BRAMNICK, RODRIGUEZ, GRABAS, ARNOLD & MANGAN, LLC Attorneys for Plaintiff /s/ Jonathan P. Arnold JONATHAN P. ARNOLD, ESQ. PHYSICIAN’S CERTIFICATION A Physician’s Certification complying with N.J.S.A. 39:6A-8a is attached to this Complaint. MID-L-006460-22 12/30/2022 3:03:36 PM Pg8of9 Trans ID: LCV20224469637 EXHIBIT “A” MID-L-006460-22 12/30/2022 3:03:36 PM Pg9of9 Trans ID: LCV20224469637 CERTIFICATION PURSUANT TO N.J,S.A, 39:64-8a OF THE AUTOMOBILE INSURANCE COST REDUCTION ACT OF 1998 1 Tam a licensed physician as defined by NLLS.A, 45:9-5.1, 2. Iam a treating physician to the plaintiff, Giovanni Hernandez-Gomez, for injuries sustained on November 30, 2021. 3 All of the opinions set forth herein are within a reasonable degree of medical probability. 4. As a result of the November 30, 2021 accident, Giovanni Hernandez Gomez sustained the following injuries: . Disc bulge at C3-4, C5-6 and C6-7 - Disc bulge at L3-4 ~ Disc herniations at L4-5 5 This certification is based on objective clinical evidence including, but not limited to: MRI of the Cervical Spine MRI of the Lumbar Spine Physical examination. 6 Any testing referred to above is not experimental in nature nor are the results of such tests dependent entirely on subjective patient response. 7 Based on my professional expertise and objective clinical evidence including my clinical findings and/or the resultsof objective medical tests, it is my opinion within a reasonable degree of medical probability that Giovanni Hernandez- Gomez has sustained a permanent injury in that Giovanni Hernandez-Gomez has/have not healed to function normally and will not heal to function normally with further medical treatment. 8 I certify under penalty of perjury that the above conclusions are true to the best of my knowledge and belief. I am aware that if the foregoing statements made by me are willfully false, I am subject to punishment. Dated: Wafrr MID-L-006460-22 12/30/2022 3:03:36 PM Pglof2 Trans ID: LCV20224469637 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-006460-22 Case Caption: HERNANDEZ-GOMEZ GIOVANNI VS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL HERNANDEZ-GOMEZ GIOV THRESHOLD) Case Initiation Date: 12/30/2022 Document Type: Complaint with Jury Demand Attorney Name: JONATHAN PETER ARNOLD Jury Demand: YES - 6 JURORS Firm Name: BRAMNICK RODRIGUEZ GRABAS ARNOLD & Is this a professional malpractice case? NO MANGAN LLC Related cases pending: NO Address: 1827 E SECOND ST If yes, list docket numbers: SCOTCH PLAINS NJ 07076 Do you anticipate adding any parties (arising out of same Phone: 9083227000 transaction or occurrence)? NO Name of Party: PLAINTIFF : Hernandez-Gomez, Giovanni Does this case involve claims related to COVID-19? NO Name of Defendant's Primary Insurance Company (if known): Geico Are sexual abuse claims alleged by: Giovanni Hernandez-Gomez? 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) 12/30/2022 /!s/ JONATHAN PETER ARNOLD Dated Signed MID-L-006460-22 12/30/2022 3:03:36 PM Pg2of2 Trans ID: LCV20224469637