Preview
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 5 Trans ID: LCV20223652027
Law Office
of
DEBRA HART
DEBRA HART ++ STEVEN I. GREENBERG
581 MAIN STREET
ANTHONY F. BELOTTA
SUITE 801
BARBARA S. SHERIDAN NATALIE O. MATLA +++
WOODBRIDGE, NJ 07095
MARY E. MCLAUGHLIN* (732) 378-4600 VANESA L. RIDRE +
CATHERINE MASTERSON Fax: (732) 378-4426 EVAN C. CAMHI +
EMMA K. BRADLEY ++
Employees of Palisades/High Point Insurance Group + NJ & NY BARS
++ NJ & PA BARS
+++ NJ NY DC & WA BARS
* CERTIFIED BY THE SUPREME COURT OF NEW
JERSEY AS A CIVIL TRIAL ATTORNEY
Attorney Direct: 732-378-4433 cell 732-403-1121 Email: ABAssist@dahart-law.com
Secretary Direct: 732-378-4449
October 14, 2022
Essex County Superior Court
50 West Market Street
Newark, NJ 07102
Re: Fernandez vs Kariqi
Our FileNo:339101956091
Docket No:ESX-L-5177-22
Dear Sir/Madam:
Enclosed please find documents listed below:
(X) Notice of Motion
(X) Certification
(X) Order
(X) Please charge the filing fee to our collateral account 144293.
(X) Please file
Very truly yours,
Anthony F. Belotta
By:_________________________
Anthony F Belotta
AB/sw
cc: Donna McKeon/Parsippany Claims Office/339101956091
Nicholas Waltman
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 2 of 5 Trans ID: LCV20223652027
Anthony F Belotta - 015651997
DEBRA HART
581 MAIN STREET, SUITE 801
WOODBRIDGE, NJ 07095
TEL: (732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Ilir Kariqi
Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
Plaintiffs, DOCKET NO.ESX-L-5177-22
Civil Action
vs. NOTICE OF MOTION TO CHANGE
VENUE
Ilir Kariqi, Government Employees Insurance
Company, John Doe 1-10 and ABC Corp. 1-
10 (names being fictitious astrue identities are
unknown at this time),
Defendants.
TO:
Nicholas Waltman Esq
Fredson Statmore Bitterman, LLC
200 Broadacres Drive
Bloomfield NJ 07003
SIRS:
PLEASE TAKE NOTICE that on 11/04/2022, at 9:00 A.M. or as soon thereafter as Counsel may be
heard, the undersigned, attorney for defendant/s, Ilir Kariqi shall apply to the Court for an Order to change venue
from ESSEX County to Passaic County.
IN SUPPORT HEREOF, we shall rely upon the Certification of Anthony F Belotta, ESQ., attached
hereto and made a part of the moving papers submitted.
IT IS respectfully requested that this matter be submitted to the Court for ruling on the papers pursuant to
the applicable provisions of Rule 1:6-2.
Law Office of Debra Hart
Anthony F. Belotta
Dated: October 14, 2022 By: ___________
Anthony F Belotta
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 3 of 5 Trans ID: LCV20223652027
PROCEDURAL HISTORY:
Complaint filed on: 8/31/2022
Summons issued: 10/7/2022
Answer filed on: 10/14/2022
Discovery End Date:
Settlement Conf:
Arbitration Date:
Trial Date:
Pursuant to Rule 1:6-2(d), the undersigned:
(X) Waives oral argument and consents to disposition on the papers
( ) Requests oral argument if opposition filed
( ) Requests oral argument
I certify that the moving party has either attempted to personally confer orally with the opposing party or
has advised the opposing party by letter that after the default occurred, that continued non-compliance with
discovery obligations will result in an appropriate Motion being made without further attempt to resolve this
matter.
PROOF OF MAILING
I hereby certify that an original and one copy of the within document has been filed with the Clerk, Superior Court
of New Jersey Essex County Superior Court 50 West Market Street Newark, NJ 07102 and that a copy of same has
been served upon all parties of record within the period of time allowed in accord with R. 1:6-4 and 4:6-1.
Law Office of Debra Hart
Anthony F. Belotta
Dated: October 14, 2022 By: ___________
Anthony F Belotta
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 4 of 5 Trans ID: LCV20223652027
CERTIFICATION
I, Anthony F Belotta of full age, hereby certify the following:
1. I am An Attorney-at-Law of the State of New Jersey, and am associated with the Law Office of Debra
Hart . I have been assigned personal handling of and am familiar with the above-captioned matter.
2. This matter pertains to an accident that occurred on June 18, 2021 on River Street in the City of
Paterson, County of Passaic, and State of New Jersey. (See a copy of the New Jersey Police Crash
Investigation Report annexed hereto as Exhibit A)
3. Involved in this accident were the plaintiff, Freddie R. Fernandez, a resident of Prospect Park, New
Jersey and defendant Ilir Kariqi, a resident of Hawthorne, New Jersey. The plaintiff’s Complaint against
co-defendant, Government Employees Insurance Company, was dismissed on September 15, 2022.
4. Pursuant to Rule 4:3-2(a), venue in this action should be placed in Passaic County, the county in which
the cause of action arose, or in which one or more of the parties to this action resided at the time of its
commencement. Neither the cause of action nor any of the parties to this action have contact with the
present county of venue.
5. I know of no settlement conference date, arbitration date or trial date.
6. I further certify that all statements contained herein are true to the best of my knowledge. I am aware that if any
such statements are willfully false, I am subject to punishment.
Anthony F. Belotta
Dated: October 14, 2022 _________________________________
Anthony F Belotta
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 5 of 5 Trans ID: LCV20223652027
Anthony F Belotta – 015651997
DEBRA HART
581 MAIN STREET, SUITE 801
WOODBRIDGE, NJ 07095
TEL: (732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Ilir Kariqi
Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
Plaintiffs, DOCKET NO.ESX-L-5177-22
Civil Action
vs. ORDER CHANGING VENUE
Ilir Kariqi, Government Employees Insurance
Company, John Doe 1-10 and ABC Corp. 1-
10 (names being fictitious as true identities
are unknown at this time),
Defendants.
THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the
defendant/s, Ilir Kariqi ; and the Court having considered the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
ORDERED that the county of venue be set down as Passaic County; and
IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties
upon its upload to eCourts.
________________________________
, J.S.C.
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 3 Trans ID: LCV20223652027
Exhibit A
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 2 of 3 Trans ID: LCV20223652027
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 3 of 3 Trans ID: LCV20223652027
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 1 Trans ID: LCV20223652027
Anthony F Belotta – 015651997
DEBRA HART
581 MAIN STREET, SUITE 801
WOODBRIDGE, NJ 07095
TEL: (732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Ilir Kariqi
Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
Plaintiffs, DOCKET NO.ESX-L-5177-22
Civil Action
vs. ORDER CHANGING VENUE
Ilir Kariqi, Government Employees Insurance
Company, John Doe 1-10 and ABC Corp. 1-
10 (names being fictitious as true identities
are unknown at this time),
Defendants.
THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the
defendant/s, Ilir Kariqi ; and the Court having considered the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
ORDERED that the county of venue be set down as Passaic County; and
IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties
upon its upload to eCourts.
________________________________
, J.S.C.
Preview
ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 5 Trans ID: LCV20223652027 Law Office of DEBRA HART DEBRA HART ++ STEVEN I. GREENBERG 581 MAIN STREET ANTHONY F. BELOTTA SUITE 801 BARBARA S. SHERIDAN NATALIE O. MATLA +++ WOODBRIDGE, NJ 07095 MARY E. MCLAUGHLIN* (732) 378-4600 VANESA L. RIDRE + CATHERINE MASTERSON Fax: (732) 378-4426 EVAN C. CAMHI + EMMA K. BRADLEY ++ Employees of Palisades/High Point Insurance Group + NJ & NY BARS ++ NJ & PA BARS +++ NJ NY DC & WA BARS * CERTIFIED BY THE SUPREME COURT OF NEW JERSEY AS A CIVIL TRIAL ATTORNEY Attorney Direct: 732-378-4433 cell 732-403-1121 Email: ABAssist@dahart-law.com Secretary Direct: 732-378-4449 October 14, 2022 Essex County Superior Court 50 West Market Street Newark, NJ 07102 Re: Fernandez vs Kariqi Our FileNo:339101956091 Docket No:ESX-L-5177-22 Dear Sir/Madam: Enclosed please find documents listed below: (X) Notice of Motion (X) Certification (X) Order (X) Please charge the filing fee to our collateral account 144293. (X) Please file Very truly yours, Anthony F. Belotta By:_________________________ Anthony F Belotta AB/sw cc: Donna McKeon/Parsippany Claims Office/339101956091 Nicholas Waltman ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 2 of 5 Trans ID: LCV20223652027 Anthony F Belotta - 015651997 DEBRA HART 581 MAIN STREET, SUITE 801 WOODBRIDGE, NJ 07095 TEL: (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Ilir Kariqi Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY Plaintiffs, DOCKET NO.ESX-L-5177-22 Civil Action vs. NOTICE OF MOTION TO CHANGE VENUE Ilir Kariqi, Government Employees Insurance Company, John Doe 1-10 and ABC Corp. 1- 10 (names being fictitious astrue identities are unknown at this time), Defendants. TO: Nicholas Waltman Esq Fredson Statmore Bitterman, LLC 200 Broadacres Drive Bloomfield NJ 07003 SIRS: PLEASE TAKE NOTICE that on 11/04/2022, at 9:00 A.M. or as soon thereafter as Counsel may be heard, the undersigned, attorney for defendant/s, Ilir Kariqi shall apply to the Court for an Order to change venue from ESSEX County to Passaic County. IN SUPPORT HEREOF, we shall rely upon the Certification of Anthony F Belotta, ESQ., attached hereto and made a part of the moving papers submitted. IT IS respectfully requested that this matter be submitted to the Court for ruling on the papers pursuant to the applicable provisions of Rule 1:6-2. Law Office of Debra Hart Anthony F. Belotta Dated: October 14, 2022 By: ___________ Anthony F Belotta ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 3 of 5 Trans ID: LCV20223652027 PROCEDURAL HISTORY: Complaint filed on: 8/31/2022 Summons issued: 10/7/2022 Answer filed on: 10/14/2022 Discovery End Date: Settlement Conf: Arbitration Date: Trial Date: Pursuant to Rule 1:6-2(d), the undersigned: (X) Waives oral argument and consents to disposition on the papers ( ) Requests oral argument if opposition filed ( ) Requests oral argument I certify that the moving party has either attempted to personally confer orally with the opposing party or has advised the opposing party by letter that after the default occurred, that continued non-compliance with discovery obligations will result in an appropriate Motion being made without further attempt to resolve this matter. PROOF OF MAILING I hereby certify that an original and one copy of the within document has been filed with the Clerk, Superior Court of New Jersey Essex County Superior Court 50 West Market Street Newark, NJ 07102 and that a copy of same has been served upon all parties of record within the period of time allowed in accord with R. 1:6-4 and 4:6-1. Law Office of Debra Hart Anthony F. Belotta Dated: October 14, 2022 By: ___________ Anthony F Belotta ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 4 of 5 Trans ID: LCV20223652027 CERTIFICATION I, Anthony F Belotta of full age, hereby certify the following: 1. I am An Attorney-at-Law of the State of New Jersey, and am associated with the Law Office of Debra Hart . I have been assigned personal handling of and am familiar with the above-captioned matter. 2. This matter pertains to an accident that occurred on June 18, 2021 on River Street in the City of Paterson, County of Passaic, and State of New Jersey. (See a copy of the New Jersey Police Crash Investigation Report annexed hereto as Exhibit A) 3. Involved in this accident were the plaintiff, Freddie R. Fernandez, a resident of Prospect Park, New Jersey and defendant Ilir Kariqi, a resident of Hawthorne, New Jersey. The plaintiff’s Complaint against co-defendant, Government Employees Insurance Company, was dismissed on September 15, 2022. 4. Pursuant to Rule 4:3-2(a), venue in this action should be placed in Passaic County, the county in which the cause of action arose, or in which one or more of the parties to this action resided at the time of its commencement. Neither the cause of action nor any of the parties to this action have contact with the present county of venue. 5. I know of no settlement conference date, arbitration date or trial date. 6. I further certify that all statements contained herein are true to the best of my knowledge. I am aware that if any such statements are willfully false, I am subject to punishment. Anthony F. Belotta Dated: October 14, 2022 _________________________________ Anthony F Belotta ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 5 of 5 Trans ID: LCV20223652027 Anthony F Belotta – 015651997 DEBRA HART 581 MAIN STREET, SUITE 801 WOODBRIDGE, NJ 07095 TEL: (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Ilir Kariqi Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY Plaintiffs, DOCKET NO.ESX-L-5177-22 Civil Action vs. ORDER CHANGING VENUE Ilir Kariqi, Government Employees Insurance Company, John Doe 1-10 and ABC Corp. 1- 10 (names being fictitious as true identities are unknown at this time), Defendants. THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the defendant/s, Ilir Kariqi ; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; ORDERED that the county of venue be set down as Passaic County; and IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. ________________________________ , J.S.C. ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 3 Trans ID: LCV20223652027 Exhibit A ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 2 of 3 Trans ID: LCV20223652027 ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 3 of 3 Trans ID: LCV20223652027 ESX-L-005177-22 10/14/2022 4:41:48 PM Pg 1 of 1 Trans ID: LCV20223652027 Anthony F Belotta – 015651997 DEBRA HART 581 MAIN STREET, SUITE 801 WOODBRIDGE, NJ 07095 TEL: (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Ilir Kariqi Freddie Fernandez, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY Plaintiffs, DOCKET NO.ESX-L-5177-22 Civil Action vs. ORDER CHANGING VENUE Ilir Kariqi, Government Employees Insurance Company, John Doe 1-10 and ABC Corp. 1- 10 (names being fictitious as true identities are unknown at this time), Defendants. THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the defendant/s, Ilir Kariqi ; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; ORDERED that the county of venue be set down as Passaic County; and IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. ________________________________ , J.S.C.