Preview
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 1 of 7 Trans ID: LCV20224277808
EARL R. UEHLING & ASSOCIATES
Harold H. Thomasson
NJ Attorney Identification No: 021701987
3000 Atrium Way, Suite 310
Mt. Laurel, New Jersey 08054
Tel No. (856) 802-2700
Employees of The Law Department
State Farm Mutual Automobile Insurance Company
ATTORNEYS FOR DEFENDANTS, JOSHUA A. WOSZCZAK AND HALEY LONG
CHRISTOPHER WAGENHALS SUPERIOR COURT OF NEW JERSEY
LAW DIVISION MONMOUTH COUNTY
Plaintiff(s), DOCKET NO: MON-L-003146-22
vs. CIVIL ACTION
JEFF WOSZCZAK, JOSHUA A.
WOSZCZAK, HALEY LONG, JOHN DOES ANSWER WITH CROSSCLAIMS AND
1-10, AND ABC CORPORATIONS 1-10, JURY TRIAL DEMAND
Defendant(s)
Defendants, Haley E. Long and Joshua Woszczak, by way of Answer to the Complaint
filed herein, state:
FIRST COUNT
1. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but
leavesthe plaintiff to hisproofs with respect thereto.
2. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but
leavesthe plaintiff to hisproofs with respect thereto.
3. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
4. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
5. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 2 of 7 Trans ID: LCV20224277808
6. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
7. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
8. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but
leavesthe plaintiff to hisproofs with respect thereto.
9. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to
hisproofs with respect thereto.
10. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to
hisproofs with respect thereto.
11. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to
hisproofs with respect thereto.
SECOND COUNT
1. The same is made hereto as was made in paragraphs one through eleven of the Previous
Count as though set forth in full.
2. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
3. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
4. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff
is left to hisproofs with respect thereto.
SEPARATE DEFENSES
1. The answering defendants were not negligent in any way whatsoever.
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 3 of 7 Trans ID: LCV20224277808
2. The answering defendants discharged each and every obligation which they owed to the
plaintiff and otherwise the answering defendants owed no duty.
3. The alleged injuries were not the proximate result of the acts or omissions of the
answering defendants.
4. The plaintiff is barred from recovery by his own negligence, said negligence being
comparatively greater than the negligence of the answering defendants.
5. The negligence, if any, was the result of the acts or omissions of someone other than the
answering defendants and not under their control.
6. The answering defendants were not negligent due to the fact that they were confronted
with a sudden emergency.
7. The complaint fails to state a cause of action upon which relief can be granted.
8. The plaintiff is barred from recovery by the entire controversy doctrine.
9. The plaintiff is barred from recovery by landowners immunity.
10. The plaintiff is barred from recovery by public policy.
11. The plaintiff is barred from recovery by res judicata.
12. The plaintiff is barred from recovery by the applicable Statute of Limitations.
13. The plaintiff has incurred medical expenses which are both unreasonable and
unnecessary or involved conditions not related to the accident.
14. The plaintiff's loss of wages is due to conditions other than injuries caused by the
accident.
15. The answering defendants are not liable due to the fact that the alleged damages were the
result of superseding and/or intervening acts of others over whom the answering defendants had
no control.
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16. The answering defendants reserve the right to move to dismiss the complaint due to
insufficiency of process.
17. The answering defendants reserve the right to move to dismiss the complaint due to
insufficiency of service of process.
18. The answering defendants deny the applicability of strict liability to this litigation.
19. The answering defendants specifically deny that they made any representations to the
plaintiff but if it is found that such representations were made, then it is denied that the plaintiff
relied on such representations.
20. The answering defendants deny any liability whatsoever due to the plaintiff failure to
mitigate damages.
21. Any injuries or damages were the result of the negligence of third parties over whom
answering defendants had neither control nor the duty to control or warn.
22. The plaintiff lacks standing to proceed with this litigation.
23. Without waiving its denial of liability to plaintiff, pursuant to the Patient Protection and
Affordable Care Act (“PPACA”) and common-law, plaintiff has a duty to mitigate the amount of
future damages for medical care by purchasing a universal health insurance policy no later than
March 31, 2014 in accordance with the Individual Mandate confided in 26 U.S.C. § 5003 et seq.
Defendants' potential liability for future medical care will therefore be limited.
24. The plaintiff’s claims are barred by waiver.
CROSS-CLAIM FOR CONTRIBUTION
The answering defendants hereby cross-claims for contribution against the co-defendant,
Jeff Woszczak under the New Jersey Joint Tortfeasors Contribution Act, N.J.S.A. 2A:53A-1, et
seq.
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 5 of 7 Trans ID: LCV20224277808
CROSS-CLAIM FOR INDEMNIFICATION
Under the facts existing in this case, the answering defendants are entitled to
indemnification from the co-defendant, Jeff Woszczak for any and all sums of money which they
may be required to pay to the plaintiffplus costs and counsel fees.
RESERVATION OF MOTION TO STRIKE
The answering defendants hereby reserves the right to move to strike the return of service
because of the failure of the plaintiff to gain personal jurisdiction, because of insufficiency of
service of process and because the Court does not have jurisdiction over the answering
defendants in this matter.
DEMAND FOR ANSWERS TO INTERROGATORIES
The answering defendants hereby demand that the plaintiff Christopher Wagenhals
provide answers to the following interrogatories: Uniform Form A Interrogatories and
Supplemental Interrogatories.
Pursuant to Rule 4:17-4. Demand is hereby made for copies of all answers to
interrogatories which the plaintiff has provided to any other party to this action.
The answering defendants hereby demand that the co-defendant, Jeff Woszczak provide
answers to the following interrogatories: Uniform Form C and C(2) Interrogatories.
HIPAA COMPLIANT AUTHORIZATION OR
REQUEST FOR PRODUCTION OF DOCUMENTS
The answering defendants hereby demand from the plaintiff an original, fully executed,
unrestricted HIPAA compliant authorization for the production and release of:
• The insurer’s file concerning universal health insurance procured by plaintiff,
pursuant to the January 1, 2014 effective Individual Mandate of the Affordable
Care Act of 2010, either through an employer, public health insurance, or the
individual policy market, in accordance with 26 U.S.C. 5003(A)(a) et seq. and
plaintiff's common law duty to mitigate damages.
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 6 of 7 Trans ID: LCV20224277808
• All records from the Centers for Medicare and Medicaid Services concerning any
application by plaintiff for federal and/or state subsidies in the procurement of
Individually Mandated universal health insurance in accordance with the
PPACA/ACA.
JURY DEMAND
The answering defendants hereby demand a trial by jury as to all issues.
DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4:25-4, the undersigned is designated as trial counsel in this matter.
CERTIFICATION
Following my initial review of this matter, it appears that there are no other actions or
arbitrations related to this suit pending or presently contemplated.
Following my initial review of this matter, it appears that there are no other persons who
should be joined as parties.
I hereby certify that the foregoing statements made by me are true. I am aware that if any
of the foregoing statements made by me are willfully false, I am subject to punishment.
Dated: December 19, 2022 Earl R. Uehling & Associates
Attorney for Defendants
Haley E. Long and Joshua Woszczak
By: _ __
Harold H. Thomasson
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 7 of 7 Trans ID: LCV20224277808
EARL R. UEHLING & ASSOCIATES
Harold H. Thomasson
NJ Attorney Identification No: 021701987
3000 Atrium Way, Suite 310
Mt. Laurel, New Jersey 08054
Tel No. (856) 802-2700
Employees of The Law Department
State Farm Mutual Automobile Insurance Company
ATTORNEYS FOR DEFENDANTS, JOSHUA A. WOSZCZAK AND HALEY LONG
CHRISTOPHER WAGENHALS SUPERIOR COURT OF NEW JERSEY
LAW DIVISION MONMOUTH
Plaintiff(s), COUNTY
vs. DOCKET NO: MON-L-003146-22
JEFF WOSZCZAK, JOSHUA A. CIVIL ACTION
WOSZCZAK, HALEY LONG, JOHN
DOES 1-10, and ABC CORPORATIONS PROOF OF ELECTRONIC MAILING
1-10, VIA NJ E-COURTS
Defendant(s)
CERTIFICATE OF SERVICE
I, Harold H. Thomasson, hereby certify that a true and correct copy of the within Answer will be
served to all counsel and unrepresented parties electronically by the E-Filing system or regular
mail or facsimile if counsel or the unrepresented party does not participate in E-Filing, on the
date of E-Filing acceptance of the document.
Earl R. Uehling & Associates
Attorney for Defendants
Haley E. Long and Joshua Woszczak
Date: December 19, 2022
_____
Harold H. Thomasson
Attorney ID#021701987
3000 Atrium Way, Suite 310
Mt. Laurel, NJ 08054
PHONE NO. (856) 802-2700
FAX NO. (855) 695-0709
MON-L-003146-22 12/19/2022
MON-L-003146-22 12/19/20224:30:31
4:30:22PM
PM Pg 1 of 1 Trans
TransID:
ID:LCV20224277808
LCV20224277808
Civil Case Information Statement
Case Details: MONMOUTH | Civil Part Docket# L-003146-22
Case Caption: WAGENHALS CHRISTOPH VS Case Type: PERSONAL INJURY
WOSZCZAK JEFF Document Type: Answer W/CrossClaim W/Jury Demand
Case Initiation Date: 11/14/2022 Jury Demand: YES - 6 JURORS
Attorney Name: HAROLD H THOMASSON Is this a professional malpractice case? NO
Firm Name: EARL R. UEHLING & ASSOCIATES Related cases pending: NO
Address: 3000 ATRIUM WAY SUITE 310 If yes, list docket numbers:
MT LAUREL NJ 08054 Do you anticipate adding any parties (arising out of same
Phone: 8568022700 transaction or occurrence)? NO
Name of Party: DEFENDANT : WOSZCZAK, JOSHUA, A Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): STATE FARM MUTUAL AUTO INS CO Are sexual abuse claims alleged by: CHRISTOPH WAGENHALS?
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)
12/19/2022 /s/ HAROLD H THOMASSON
Dated Signed
Preview
MON-L-003146-22 12/19/2022 4:30:31 PM Pg 1 of 7 Trans ID: LCV20224277808 EARL R. UEHLING & ASSOCIATES Harold H. Thomasson NJ Attorney Identification No: 021701987 3000 Atrium Way, Suite 310 Mt. Laurel, New Jersey 08054 Tel No. (856) 802-2700 Employees of The Law Department State Farm Mutual Automobile Insurance Company ATTORNEYS FOR DEFENDANTS, JOSHUA A. WOSZCZAK AND HALEY LONG CHRISTOPHER WAGENHALS SUPERIOR COURT OF NEW JERSEY LAW DIVISION MONMOUTH COUNTY Plaintiff(s), DOCKET NO: MON-L-003146-22 vs. CIVIL ACTION JEFF WOSZCZAK, JOSHUA A. WOSZCZAK, HALEY LONG, JOHN DOES ANSWER WITH CROSSCLAIMS AND 1-10, AND ABC CORPORATIONS 1-10, JURY TRIAL DEMAND Defendant(s) Defendants, Haley E. Long and Joshua Woszczak, by way of Answer to the Complaint filed herein, state: FIRST COUNT 1. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but leavesthe plaintiff to hisproofs with respect thereto. 2. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but leavesthe plaintiff to hisproofs with respect thereto. 3. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 4. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 5. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. MON-L-003146-22 12/19/2022 4:30:31 PM Pg 2 of 7 Trans ID: LCV20224277808 6. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 7. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 8. The answering defendantsneither admitsnor deniesthe allegations of thisparagraph but leavesthe plaintiff to hisproofs with respect thereto. 9. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to hisproofs with respect thereto. 10. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to hisproofs with respect thereto. 11. Any negligence on the part of the answering defendantsis denied and the plaintiff is left to hisproofs with respect thereto. SECOND COUNT 1. The same is made hereto as was made in paragraphs one through eleven of the Previous Count as though set forth in full. 2. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 3. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. 4. The allegations of thisparagraph are not directed to the answering defendantsand the plaintiff is left to hisproofs with respect thereto. SEPARATE DEFENSES 1. The answering defendants were not negligent in any way whatsoever. MON-L-003146-22 12/19/2022 4:30:31 PM Pg 3 of 7 Trans ID: LCV20224277808 2. The answering defendants discharged each and every obligation which they owed to the plaintiff and otherwise the answering defendants owed no duty. 3. The alleged injuries were not the proximate result of the acts or omissions of the answering defendants. 4. The plaintiff is barred from recovery by his own negligence, said negligence being comparatively greater than the negligence of the answering defendants. 5. The negligence, if any, was the result of the acts or omissions of someone other than the answering defendants and not under their control. 6. The answering defendants were not negligent due to the fact that they were confronted with a sudden emergency. 7. The complaint fails to state a cause of action upon which relief can be granted. 8. The plaintiff is barred from recovery by the entire controversy doctrine. 9. The plaintiff is barred from recovery by landowners immunity. 10. The plaintiff is barred from recovery by public policy. 11. The plaintiff is barred from recovery by res judicata. 12. The plaintiff is barred from recovery by the applicable Statute of Limitations. 13. The plaintiff has incurred medical expenses which are both unreasonable and unnecessary or involved conditions not related to the accident. 14. The plaintiff's loss of wages is due to conditions other than injuries caused by the accident. 15. The answering defendants are not liable due to the fact that the alleged damages were the result of superseding and/or intervening acts of others over whom the answering defendants had no control. MON-L-003146-22 12/19/2022 4:30:31 PM Pg 4 of 7 Trans ID: LCV20224277808 16. The answering defendants reserve the right to move to dismiss the complaint due to insufficiency of process. 17. The answering defendants reserve the right to move to dismiss the complaint due to insufficiency of service of process. 18. The answering defendants deny the applicability of strict liability to this litigation. 19. The answering defendants specifically deny that they made any representations to the plaintiff but if it is found that such representations were made, then it is denied that the plaintiff relied on such representations. 20. The answering defendants deny any liability whatsoever due to the plaintiff failure to mitigate damages. 21. Any injuries or damages were the result of the negligence of third parties over whom answering defendants had neither control nor the duty to control or warn. 22. The plaintiff lacks standing to proceed with this litigation. 23. Without waiving its denial of liability to plaintiff, pursuant to the Patient Protection and Affordable Care Act (“PPACA”) and common-law, plaintiff has a duty to mitigate the amount of future damages for medical care by purchasing a universal health insurance policy no later than March 31, 2014 in accordance with the Individual Mandate confided in 26 U.S.C. § 5003 et seq. Defendants' potential liability for future medical care will therefore be limited. 24. The plaintiff’s claims are barred by waiver. CROSS-CLAIM FOR CONTRIBUTION The answering defendants hereby cross-claims for contribution against the co-defendant, Jeff Woszczak under the New Jersey Joint Tortfeasors Contribution Act, N.J.S.A. 2A:53A-1, et seq. MON-L-003146-22 12/19/2022 4:30:31 PM Pg 5 of 7 Trans ID: LCV20224277808 CROSS-CLAIM FOR INDEMNIFICATION Under the facts existing in this case, the answering defendants are entitled to indemnification from the co-defendant, Jeff Woszczak for any and all sums of money which they may be required to pay to the plaintiffplus costs and counsel fees. RESERVATION OF MOTION TO STRIKE The answering defendants hereby reserves the right to move to strike the return of service because of the failure of the plaintiff to gain personal jurisdiction, because of insufficiency of service of process and because the Court does not have jurisdiction over the answering defendants in this matter. DEMAND FOR ANSWERS TO INTERROGATORIES The answering defendants hereby demand that the plaintiff Christopher Wagenhals provide answers to the following interrogatories: Uniform Form A Interrogatories and Supplemental Interrogatories. Pursuant to Rule 4:17-4. Demand is hereby made for copies of all answers to interrogatories which the plaintiff has provided to any other party to this action. The answering defendants hereby demand that the co-defendant, Jeff Woszczak provide answers to the following interrogatories: Uniform Form C and C(2) Interrogatories. HIPAA COMPLIANT AUTHORIZATION OR REQUEST FOR PRODUCTION OF DOCUMENTS The answering defendants hereby demand from the plaintiff an original, fully executed, unrestricted HIPAA compliant authorization for the production and release of: • The insurer’s file concerning universal health insurance procured by plaintiff, pursuant to the January 1, 2014 effective Individual Mandate of the Affordable Care Act of 2010, either through an employer, public health insurance, or the individual policy market, in accordance with 26 U.S.C. 5003(A)(a) et seq. and plaintiff's common law duty to mitigate damages. MON-L-003146-22 12/19/2022 4:30:31 PM Pg 6 of 7 Trans ID: LCV20224277808 • All records from the Centers for Medicare and Medicaid Services concerning any application by plaintiff for federal and/or state subsidies in the procurement of Individually Mandated universal health insurance in accordance with the PPACA/ACA. JURY DEMAND The answering defendants hereby demand a trial by jury as to all issues. DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4:25-4, the undersigned is designated as trial counsel in this matter. CERTIFICATION Following my initial review of this matter, it appears that there are no other actions or arbitrations related to this suit pending or presently contemplated. Following my initial review of this matter, it appears that there are no other persons who should be joined as parties. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: December 19, 2022 Earl R. Uehling & Associates Attorney for Defendants Haley E. Long and Joshua Woszczak By: _ __ Harold H. Thomasson MON-L-003146-22 12/19/2022 4:30:31 PM Pg 7 of 7 Trans ID: LCV20224277808 EARL R. UEHLING & ASSOCIATES Harold H. Thomasson NJ Attorney Identification No: 021701987 3000 Atrium Way, Suite 310 Mt. Laurel, New Jersey 08054 Tel No. (856) 802-2700 Employees of The Law Department State Farm Mutual Automobile Insurance Company ATTORNEYS FOR DEFENDANTS, JOSHUA A. WOSZCZAK AND HALEY LONG CHRISTOPHER WAGENHALS SUPERIOR COURT OF NEW JERSEY LAW DIVISION MONMOUTH Plaintiff(s), COUNTY vs. DOCKET NO: MON-L-003146-22 JEFF WOSZCZAK, JOSHUA A. CIVIL ACTION WOSZCZAK, HALEY LONG, JOHN DOES 1-10, and ABC CORPORATIONS PROOF OF ELECTRONIC MAILING 1-10, VIA NJ E-COURTS Defendant(s) CERTIFICATE OF SERVICE I, Harold H. Thomasson, hereby certify that a true and correct copy of the within Answer will be served to all counsel and unrepresented parties electronically by the E-Filing system or regular mail or facsimile if counsel or the unrepresented party does not participate in E-Filing, on the date of E-Filing acceptance of the document. Earl R. Uehling & Associates Attorney for Defendants Haley E. Long and Joshua Woszczak Date: December 19, 2022 _____ Harold H. Thomasson Attorney ID#021701987 3000 Atrium Way, Suite 310 Mt. Laurel, NJ 08054 PHONE NO. (856) 802-2700 FAX NO. (855) 695-0709 MON-L-003146-22 12/19/2022 MON-L-003146-22 12/19/20224:30:31 4:30:22PM PM Pg 1 of 1 Trans TransID: ID:LCV20224277808 LCV20224277808 Civil Case Information Statement Case Details: MONMOUTH | Civil Part Docket# L-003146-22 Case Caption: WAGENHALS CHRISTOPH VS Case Type: PERSONAL INJURY WOSZCZAK JEFF Document Type: Answer W/CrossClaim W/Jury Demand Case Initiation Date: 11/14/2022 Jury Demand: YES - 6 JURORS Attorney Name: HAROLD H THOMASSON Is this a professional malpractice case? NO Firm Name: EARL R. UEHLING & ASSOCIATES Related cases pending: NO Address: 3000 ATRIUM WAY SUITE 310 If yes, list docket numbers: MT LAUREL NJ 08054 Do you anticipate adding any parties (arising out of same Phone: 8568022700 transaction or occurrence)? NO Name of Party: DEFENDANT : WOSZCZAK, JOSHUA, A Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): STATE FARM MUTUAL AUTO INS CO Are sexual abuse claims alleged by: CHRISTOPH WAGENHALS? 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) 12/19/2022 /s/ HAROLD H THOMASSON Dated Signed