Preview
MON-L-003410-22 12/13/2022 1:39:22 PM Pglof4 Trans ID: LCV20224200140
Russell Macnow, Esq. - 020571993
Macnow & Papaleo Attorneys at Law
265 Route 34, Suite E
Colts Neck, NJ 07722
T (732) 780-0040
F (732) 780-0090
m@macnowlaw.com
Attorneys for Plaintiff
Our File No.:. C1937
JEFFREY SISCO and VESNA
SISCO, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
Plaintiffs, DOCKET NO. MON-L-
a Civil Action
QUICK CHEK CORPORATION, COMPLAINT
ABC COMPANIES 1-100 (fictitious
names) and JOHN DOES 1-100
(fictitious names),
Defendants.
Plaintiffs, by way of Complaint against the defendants, hereby say:
FIRST COUNT
1. At all times relevant hereto, plaintiffs were residents of the Township of
Manalapan, County of Monmouth and State of New Jersey.
2. At all times relevant hereto, defendant, Quick Chek Corporation, was a New Jersey
corporation with various stores in the State of New Jersey including the one located at 1
Wilson Avenue, Englishtown, New Jersey.
3. On or about March 22, 2021, plaintiff, Jeffrey Sisco, was a lawful invitee at the
Quick Chek store located a 1 Wilson Avenue, Englishtown, New Jersey when he was caused
to fall as a result of the careless, negligent and reckless construction and/or maintenance of
MON-L-003410-22 12/13/2022 1:39:22 PM Pg2of4 Trans ID: LCV20224200140
the parking lot by defendant, Quick Chek Corporation, causing him to sustain serious.and
permanent injuries as a result of which he has been caused to and did seek medical
attention in an effort to cure himself, was and continues to prevent him from attending to
his usual business and was otherwise seriously and permanently injured.
WHEREFORE, plaintiff, Jeffrey Sisco, demands judgment against the defendant,
Quick Chek Corporation, for compensatory damages, consequential damages together with
attorneys’ fees, costs, prejudgment interest and such other relief as the court may deem just
and proper.
SECOND COUNT
1. Plaintiffs repeat, reiterate and incorporate by reference the allegations contained in
Count One of the Complaint as if set forth at length herein.
2. At all times relevant hereto, defendants, ABC Companies 1-100 (fictitious names)
and John Does 1-100 (fictitious names), whose identities are presently unknown, are
corporate entities and/or individuals who constructed and/or maintained the parking lot in
the Quick Chek store located at 1 Wilson Avenue, Englishtown, New Jersey and are liable
to the plaintiffs for the same reasons and to the same extent as defendant, Quick Chek
Corporation.
WHEREFORE, plaintiffs, Jeffrey Sisco and Vesna Sisco, demand judgment against
the defendants, ABC Companies 1-100 (fictitious names) and John Does 1-100 (fictitious
names), for compensatory damages, consequential damages together with attorneys’ fees,
costs, prejudgment interest and such other relief as the court may deem just and proper.
THIRD COUNT
1. Plaintiffs repeat, reiterate and incorporate by reference the allegations contained in
Counts One and Two of the Complaint as if set forth at length herein.
2. At all times relevant hereto, Vesna Sisco, was the spouse of plaintiff, Jeffrey Sisco.
MON-L-003410-22 12/13/2022 1:39:22 PM Pg3o0f4 Trans ID: LCV20224200140
3. As a direct and proximate result of the carelessness, negligence and recklessness of the
defendants, plaintiff, Vesna Sisco, has been and will be required to expend large sums of
money in order to effectuate a cure for her husband, as well as the services of her husband
and has otherwise been damaged.
WHEREFORE, plaintiff, Vesna Sisco, demands judgment against the defendants for
compensatory damages, consequential damages together with attorneys’ fees, costs,
prejudgment interest and such other reliefas the court may deem just and proper.
JURY DEMAND
Plaintiff hereby demands a trial by jury as to all issues.
Quoton. fi.
Russell Macnow, Esq.
Attorney for Plaintiff
CERTIFICATION NO OTHER ACTION PENDING
I certify, pursuant to R. 4:5-1(b)(2) that the matter in controversy is not the subject of
any other action or arbitration proceeding, nor are they contemplated. To the best of my
knowledge and information, no other parties should be joined in this action.
GaspIn
Russell Macn ow, Esq.
Attorney for Plaintiff
DATED: December 13, 2022
MON-L-003410-22 12/13/2022 1:39:22 PM Pg4of4 Trans ID: LCV20224200140
DESIGNATION OF TRIAL COUNSEL
Pursuant to the provisions of R. 4:25-4, the Court is advised that Russell Macnow,
Esq., is hereby designated as trial counsel.
uss fh
Russell Macnow, Esq.
Attorney for Plaintiff
MON-L-003410-22 12/13/2022 1:39:22 PM Pglof2 Trans ID: LCV20224200140
Civil Case Information Statement
Case Details: MONMOUTH | Civil Part Docket# L-003410-22
Case Caption: SISCO JEFFREY VS QUICK CHEK Case Type: PERSONAL INJURY
CORPORATI ON Document Type: Complaint with Jury Demand
Case Initiation Date: 12/13/2022 Jury Demand: YES - 6 JURORS
Attorney Name: LAUREN PAPALEO Is this a professional malpractice case? NO
Firm Name: RUSSELL MACNOW, LLC Related cases pending: NO
Address: 265 ROUTE 34 SUITE E If yes, list docket numbers:
COLTS NECK NJ 07722 Do you anticipate adding any parties (arising out of same
Phone: 7327800040 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Sisco, Jeffrey Does this case involve claims related to COVID-19? NO
Name of Defendant's Primary Insurance Company
(if known): None Are sexual abuse claims alleged by: Jeffrey Sisco? NO
Are sexual abuse claims alleged by: Vesna Sisco? 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)
12/13/2022 /s/ LAUREN PAPALEO
Dated Signed
MON-L-003410-22 12/13/2022 1:39:22 PM Pg2of2 Trans ID: LCV20224200140
Preview
MON-L-003410-22 12/13/2022 1:39:22 PM Pglof4 Trans ID: LCV20224200140 Russell Macnow, Esq. - 020571993 Macnow & Papaleo Attorneys at Law 265 Route 34, Suite E Colts Neck, NJ 07722 T (732) 780-0040 F (732) 780-0090 m@macnowlaw.com Attorneys for Plaintiff Our File No.:. C1937 JEFFREY SISCO and VESNA SISCO, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MONMOUTH COUNTY Plaintiffs, DOCKET NO. MON-L- a Civil Action QUICK CHEK CORPORATION, COMPLAINT ABC COMPANIES 1-100 (fictitious names) and JOHN DOES 1-100 (fictitious names), Defendants. Plaintiffs, by way of Complaint against the defendants, hereby say: FIRST COUNT 1. At all times relevant hereto, plaintiffs were residents of the Township of Manalapan, County of Monmouth and State of New Jersey. 2. At all times relevant hereto, defendant, Quick Chek Corporation, was a New Jersey corporation with various stores in the State of New Jersey including the one located at 1 Wilson Avenue, Englishtown, New Jersey. 3. On or about March 22, 2021, plaintiff, Jeffrey Sisco, was a lawful invitee at the Quick Chek store located a 1 Wilson Avenue, Englishtown, New Jersey when he was caused to fall as a result of the careless, negligent and reckless construction and/or maintenance of MON-L-003410-22 12/13/2022 1:39:22 PM Pg2of4 Trans ID: LCV20224200140 the parking lot by defendant, Quick Chek Corporation, causing him to sustain serious.and permanent injuries as a result of which he has been caused to and did seek medical attention in an effort to cure himself, was and continues to prevent him from attending to his usual business and was otherwise seriously and permanently injured. WHEREFORE, plaintiff, Jeffrey Sisco, demands judgment against the defendant, Quick Chek Corporation, for compensatory damages, consequential damages together with attorneys’ fees, costs, prejudgment interest and such other relief as the court may deem just and proper. SECOND COUNT 1. Plaintiffs repeat, reiterate and incorporate by reference the allegations contained in Count One of the Complaint as if set forth at length herein. 2. At all times relevant hereto, defendants, ABC Companies 1-100 (fictitious names) and John Does 1-100 (fictitious names), whose identities are presently unknown, are corporate entities and/or individuals who constructed and/or maintained the parking lot in the Quick Chek store located at 1 Wilson Avenue, Englishtown, New Jersey and are liable to the plaintiffs for the same reasons and to the same extent as defendant, Quick Chek Corporation. WHEREFORE, plaintiffs, Jeffrey Sisco and Vesna Sisco, demand judgment against the defendants, ABC Companies 1-100 (fictitious names) and John Does 1-100 (fictitious names), for compensatory damages, consequential damages together with attorneys’ fees, costs, prejudgment interest and such other relief as the court may deem just and proper. THIRD COUNT 1. Plaintiffs repeat, reiterate and incorporate by reference the allegations contained in Counts One and Two of the Complaint as if set forth at length herein. 2. At all times relevant hereto, Vesna Sisco, was the spouse of plaintiff, Jeffrey Sisco. MON-L-003410-22 12/13/2022 1:39:22 PM Pg3o0f4 Trans ID: LCV20224200140 3. As a direct and proximate result of the carelessness, negligence and recklessness of the defendants, plaintiff, Vesna Sisco, has been and will be required to expend large sums of money in order to effectuate a cure for her husband, as well as the services of her husband and has otherwise been damaged. WHEREFORE, plaintiff, Vesna Sisco, demands judgment against the defendants for compensatory damages, consequential damages together with attorneys’ fees, costs, prejudgment interest and such other reliefas the court may deem just and proper. JURY DEMAND Plaintiff hereby demands a trial by jury as to all issues. Quoton. fi. Russell Macnow, Esq. Attorney for Plaintiff CERTIFICATION NO OTHER ACTION PENDING I certify, pursuant to R. 4:5-1(b)(2) that the matter in controversy is not the subject of any other action or arbitration proceeding, nor are they contemplated. To the best of my knowledge and information, no other parties should be joined in this action. GaspIn Russell Macn ow, Esq. Attorney for Plaintiff DATED: December 13, 2022 MON-L-003410-22 12/13/2022 1:39:22 PM Pg4of4 Trans ID: LCV20224200140 DESIGNATION OF TRIAL COUNSEL Pursuant to the provisions of R. 4:25-4, the Court is advised that Russell Macnow, Esq., is hereby designated as trial counsel. uss fh Russell Macnow, Esq. Attorney for Plaintiff MON-L-003410-22 12/13/2022 1:39:22 PM Pglof2 Trans ID: LCV20224200140 Civil Case Information Statement Case Details: MONMOUTH | Civil Part Docket# L-003410-22 Case Caption: SISCO JEFFREY VS QUICK CHEK Case Type: PERSONAL INJURY CORPORATI ON Document Type: Complaint with Jury Demand Case Initiation Date: 12/13/2022 Jury Demand: YES - 6 JURORS Attorney Name: LAUREN PAPALEO Is this a professional malpractice case? NO Firm Name: RUSSELL MACNOW, LLC Related cases pending: NO Address: 265 ROUTE 34 SUITE E If yes, list docket numbers: COLTS NECK NJ 07722 Do you anticipate adding any parties (arising out of same Phone: 7327800040 transaction or occurrence)? NO Name of Party: PLAINTIFF : Sisco, Jeffrey Does this case involve claims related to COVID-19? NO Name of Defendant's Primary Insurance Company (if known): None Are sexual abuse claims alleged by: Jeffrey Sisco? NO Are sexual abuse claims alleged by: Vesna Sisco? 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) 12/13/2022 /s/ LAUREN PAPALEO Dated Signed MON-L-003410-22 12/13/2022 1:39:22 PM Pg2of2 Trans ID: LCV20224200140