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MID-L-000377-23 01/23/2023 10:41:37 AM Pg 1 of 4 Trans ID: LCV2023334394
JOSEPH C. LIGUORI, ESQ.
Attorney ID No. 033222001
MAZRAANI & LIGUORI, LLP
57 Paterson Street
New Brunswick, NJ 08901
(732) 951-3100
Attorney for Plaintiff, Milton Colbert
Plaintiff(s), SUPERIOR COURT OF NEW JERSEY
MIDDLESEX COUNTY
MILTON COLBERT, LAW DIVISION
vs. DOCKET NO.
Defendant(s), CIVIL ACTION
VALTER PEIXOTO, JAK COMPLAINT
CONSTRUCTION CORP. D/B/A
DIAMOND CONSTRUCTION AND
JOHN DOES 1-10 AND ABC
CORPORATIONS 1-10 (fictitious names)
Plaintiff(s), MILTON COLBERT, residing in New Jersey, County of Middlesex, by way
of Complaint, say(s):
FIRST COUNT
1. On or about May 21, 2021, at approximately 4:24 p.m.., Plaintiff, MILTON
COLBERT, was travelling in a vehicle on Edgeboro Rd. in East Brunswick, when he was struck
by a vehicle operated by Defendant VALTER PEIXOTO.
2. At the aforesaid time and place, Defendant, VALTER PEIXOTO, was negligent in the
operation of his automobile and such negligence caused a motor vehicle accident to occur.
3. As a result of the negligence of Defendant VALTER PEIXOTO, Plaintiff, MILTON
COLBERT, suffered severe and permanent bodily injuries for which he has obtained medical
treatment, and which caused him great pain and suffering, incapacitated him from pursuing his
usual activities and left him with permanent disabilities that will in the future similarly
incapacitate him, cause him pain and suffering, and require medical treatment.
MID-L-000377-23 01/23/2023 10:41:37 AM Pg 2 of 4 Trans ID: LCV2023334394
4. WHEREFORE, Plaintiffs(s), MILTON COLBERT, DEMAND(S) judgment against
the defendant(s) together with interest and costs of suit.
SECOND COUNT
5. Plaintiff(s) repeats and re-alleges the preceding allegations as if set forth at length
herein.
6. Defendant, VALTER PEIXOTO, was at all times an employee, agent, representative,
authorized driver or acting at the behest of Defendant, JAK CONSTRUCTION CORP. D/B/A
DIAMOND CONSTRUCTION.
7. Defendant JAK CONSTRUCTION CORP. D/B/A DIAMOND CONSTRUCTION., is
vicariously responsible for the negligence of the Defendant, VALTER PEIXOTO.
8. As a result of the negligence of Defendant, JAK CONSTRUCTION CORP. D/B/A
DIAMOND CONSTRUCTION, Plaintiff, MARK BARSOUM, suffered severe and permanent
bodily injuries for which he has obtained medical treatment, and which caused him great pain
and suffering, incapacitated him from pursuing his usual activities and left him with permanent
disabilities that will in the future similarly incapacitate him, cause him pain and suffering, and
require medical treatment.
9. WHEREFORE, Plaintiffs(s), MARK BARSOUM, DEMAND(S) judgment against the
defendant(s) together with interest and costs of suit.
THIRD COUNT
10. Defendants John Does 1-10 and ABC Corporations 1-10 are fictitious names intended
to represent additional persons or legal entities that may have caused the accidents and/or
plaintiff’s damages through their negligence or who are otherwise vicariously liable for the
MID-L-000377-23 01/23/2023 10:41:37 AM Pg 3 of 4 Trans ID: LCV2023334394
negligence of the named defendants and that cannot be identified at this time but may be
identified through the course of discovery.
11. WHEREFORE, Plaintiff(s) demands judgment against defendant, John Does 1-10
and ABC Corporations 1-10, jointly, severally and/or in the alternative, on the Third Count
herein for compensatory damages together with interest and costs of suit, and other remedies
allowed by law.
JURY DEMAND
Please be advised that the Plaintiff(s), MILTON COLBERT, hereby demand(s) a trial by
jury on all issues so triable.
TRIAL COUNSEL DESIGNATION
Pursuant to Rule 4:25-4, Joseph C. Liguori, Esq. has been designated as trial counsel on
behalf of the Plaintiff(s) in the above-captioned matter.
CERTIFICATION
1. Pursuant to Rule 4:5-1, the undersigned hereby certifies that at the time of filing
of this pleading, the matter in controversy is not the subject of any other action pending in any
Court and/or Arbitration proceeding.
2. I also understand that at this time there are no other parties to my knowledge that
should be named in this lawsuit.
3. I 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.
MAZRAANI & LIGUORI, LLP
Attorneys for Plaintiff(s), MILTON COLBERT
MID-L-000377-23 01/23/2023 10:41:37 AM Pg 4 of 4 Trans ID: LCV2023334394
/s/ Joseph Liguori
By: _________________________________
Joseph C. Liguori, Esq.
Dated: January 20, 2023
MID-L-000377-23 01/23/2023
MID-L-000377-23 01/23/202310:41:37
10:41:37AM
AM Pg 1 of 1 Trans
TransID:
ID:LCV2023334394
LCV2023334394
Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-000377-23
Case Caption: COLBERT MILTON VS PEIXOTO VALTER Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
Case Initiation Date: 01/23/2023 VERBAL THRESHOLD)
Attorney Name: JOSEPH C LIGUORI Document Type: Complaint with Jury Demand
Firm Name: MAZRAANI & LIGUORI LLP Jury Demand: YES - 6 JURORS
Address: 57 PATERSON ST Is this a professional malpractice case? NO
NEW BRUNSWICK NJ 08901 Related cases pending: NO
Phone: 7329513100 If yes, list docket numbers:
Name of Party: PLAINTIFF : COLBERT, MILTON 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: MILTON COLBERT? 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)
01/23/2023 /s/ JOSEPH C LIGUORI
Dated Signed
Preview
MID-L-000377-23 01/23/2023 10:41:37 AM Pg 1 of 4 Trans ID: LCV2023334394 JOSEPH C. LIGUORI, ESQ. Attorney ID No. 033222001 MAZRAANI & LIGUORI, LLP 57 Paterson Street New Brunswick, NJ 08901 (732) 951-3100 Attorney for Plaintiff, Milton Colbert Plaintiff(s), SUPERIOR COURT OF NEW JERSEY MIDDLESEX COUNTY MILTON COLBERT, LAW DIVISION vs. DOCKET NO. Defendant(s), CIVIL ACTION VALTER PEIXOTO, JAK COMPLAINT CONSTRUCTION CORP. D/B/A DIAMOND CONSTRUCTION AND JOHN DOES 1-10 AND ABC CORPORATIONS 1-10 (fictitious names) Plaintiff(s), MILTON COLBERT, residing in New Jersey, County of Middlesex, by way of Complaint, say(s): FIRST COUNT 1. On or about May 21, 2021, at approximately 4:24 p.m.., Plaintiff, MILTON COLBERT, was travelling in a vehicle on Edgeboro Rd. in East Brunswick, when he was struck by a vehicle operated by Defendant VALTER PEIXOTO. 2. At the aforesaid time and place, Defendant, VALTER PEIXOTO, was negligent in the operation of his automobile and such negligence caused a motor vehicle accident to occur. 3. As a result of the negligence of Defendant VALTER PEIXOTO, Plaintiff, MILTON COLBERT, suffered severe and permanent bodily injuries for which he has obtained medical treatment, and which caused him great pain and suffering, incapacitated him from pursuing his usual activities and left him with permanent disabilities that will in the future similarly incapacitate him, cause him pain and suffering, and require medical treatment. MID-L-000377-23 01/23/2023 10:41:37 AM Pg 2 of 4 Trans ID: LCV2023334394 4. WHEREFORE, Plaintiffs(s), MILTON COLBERT, DEMAND(S) judgment against the defendant(s) together with interest and costs of suit. SECOND COUNT 5. Plaintiff(s) repeats and re-alleges the preceding allegations as if set forth at length herein. 6. Defendant, VALTER PEIXOTO, was at all times an employee, agent, representative, authorized driver or acting at the behest of Defendant, JAK CONSTRUCTION CORP. D/B/A DIAMOND CONSTRUCTION. 7. Defendant JAK CONSTRUCTION CORP. D/B/A DIAMOND CONSTRUCTION., is vicariously responsible for the negligence of the Defendant, VALTER PEIXOTO. 8. As a result of the negligence of Defendant, JAK CONSTRUCTION CORP. D/B/A DIAMOND CONSTRUCTION, Plaintiff, MARK BARSOUM, suffered severe and permanent bodily injuries for which he has obtained medical treatment, and which caused him great pain and suffering, incapacitated him from pursuing his usual activities and left him with permanent disabilities that will in the future similarly incapacitate him, cause him pain and suffering, and require medical treatment. 9. WHEREFORE, Plaintiffs(s), MARK BARSOUM, DEMAND(S) judgment against the defendant(s) together with interest and costs of suit. THIRD COUNT 10. Defendants John Does 1-10 and ABC Corporations 1-10 are fictitious names intended to represent additional persons or legal entities that may have caused the accidents and/or plaintiff’s damages through their negligence or who are otherwise vicariously liable for the MID-L-000377-23 01/23/2023 10:41:37 AM Pg 3 of 4 Trans ID: LCV2023334394 negligence of the named defendants and that cannot be identified at this time but may be identified through the course of discovery. 11. WHEREFORE, Plaintiff(s) demands judgment against defendant, John Does 1-10 and ABC Corporations 1-10, jointly, severally and/or in the alternative, on the Third Count herein for compensatory damages together with interest and costs of suit, and other remedies allowed by law. JURY DEMAND Please be advised that the Plaintiff(s), MILTON COLBERT, hereby demand(s) a trial by jury on all issues so triable. TRIAL COUNSEL DESIGNATION Pursuant to Rule 4:25-4, Joseph C. Liguori, Esq. has been designated as trial counsel on behalf of the Plaintiff(s) in the above-captioned matter. CERTIFICATION 1. Pursuant to Rule 4:5-1, the undersigned hereby certifies that at the time of filing of this pleading, the matter in controversy is not the subject of any other action pending in any Court and/or Arbitration proceeding. 2. I also understand that at this time there are no other parties to my knowledge that should be named in this lawsuit. 3. I 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. MAZRAANI & LIGUORI, LLP Attorneys for Plaintiff(s), MILTON COLBERT MID-L-000377-23 01/23/2023 10:41:37 AM Pg 4 of 4 Trans ID: LCV2023334394 /s/ Joseph Liguori By: _________________________________ Joseph C. Liguori, Esq. Dated: January 20, 2023 MID-L-000377-23 01/23/2023 MID-L-000377-23 01/23/202310:41:37 10:41:37AM AM Pg 1 of 1 Trans TransID: ID:LCV2023334394 LCV2023334394 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-000377-23 Case Caption: COLBERT MILTON VS PEIXOTO VALTER Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- Case Initiation Date: 01/23/2023 VERBAL THRESHOLD) Attorney Name: JOSEPH C LIGUORI Document Type: Complaint with Jury Demand Firm Name: MAZRAANI & LIGUORI LLP Jury Demand: YES - 6 JURORS Address: 57 PATERSON ST Is this a professional malpractice case? NO NEW BRUNSWICK NJ 08901 Related cases pending: NO Phone: 7329513100 If yes, list docket numbers: Name of Party: PLAINTIFF : COLBERT, MILTON 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: MILTON COLBERT? 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) 01/23/2023 /s/ JOSEPH C LIGUORI Dated Signed