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OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 1 of 13 Trans ID: LCV20223865229
LAW OFFICES OF JAMES H. ROHLFING 2022115901
By: Gregory J. Guido, Esquire – Attorney ID# 030442005
5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053
Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903
(856) 703-2130
(855) 857-9823 fax
Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods
: SUPERIOR COURT OF NEW JERSEY
LORI CARR, : LAW DIVISION
: OCEAN COUNTY
Plaintiff, :
v. : DOCKET NO. OCN-L-2045-22
:
:
ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION
D/B/A FERRERA FOODS AND CENTO FINE :
FOODS; MULBERRY STREET; JOHN DOES : ANSWER TO PLAINTIFFS’ COMPLAINT,
1-5; SALLY ROES 1-10; RICHARD ROES 1-5; : SEPARATE DEFENSES, CROSSCLAIMS,
ABC CORPORATIONS 1-5 & XYZ : DEMAND FOR JURY TRIAL, DEMAND
DISTRUBUTOR CORPORATIONS 1-5, : FOR INTERROGATORIES,
: CERTIFICATIONS
Defendants. :
:
:
Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods, by way of
answer to the Complaint, says:
1. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 1, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
2. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
3. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 3, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
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4. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
5. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
6. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
7. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 7, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
8. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 8, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
9. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
10. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 10, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
11. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 11, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
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WHEREFORE, Defendant Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods
demands judgment in its favor dismissing this Count of the Complaint and awarding costs.
FIRST COUNT
1. Repeated allegations are answered as heretofore.
2. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
3. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
4. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
5. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
6. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
7. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
8. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no
answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to
Answering Defendant.
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9. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 9, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial.
WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint
and awarding costs.
SECOND COUNT
1. Repeated allegations are answered as heretofore.
2. Answering Defendant is without information or knowledge sufficient to form a belief as to
the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and
strict proof thereof is demanded at the time of Trial. Answering Defendant is not the manufacturer of any
such product as alleged in this Paragraph. Upon information and belief, the manufacturer is situated in the
country of Italy.
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint
and awarding costs.
THIRD COUNT
1. Repeated allegations are answered as heretofore.
2. Denied as to Answering Defendant.
3. Denied as to Answering Defendant.
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WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint
and awarding costs.
SEPARATE DEFENSES
1. Answering Defendant performed each and every duty and obligation owed to Plaintiff.
2. Answering Defendant acted reasonably under all of the circumstances.
3. Answering Defendant did not commit any negligence which was the proximate cause of
the injuries alleged.
4. Any injuries and/or damages allegedly sustained by Plaintiff were the result of the
negligence and/or contributory negligence of said Plaintiff.
5. Plaintiff is barred from recovery by contributory negligence, which negligence was
greater than that of Answering Defendant.
6. Plaintiff's claim against Answering Defendant is eliminated and/or reduced by the
applicable provisions of the New Jersey Comparative Negligence Act, N.J.S.A. 2A:15-5.1 et seq.
7. Defendants are not liable for more than its proper percentage of any award, as set forth in
N.J.S.A. 2A:15-5.1 et seq.
8. Any injuries and/or damages allegedly sustained by Plaintiff were the result of the sole
negligence and/or contributory negligence of a third party or parties over whom Answering Defendants had
no control or right of control.
9. Plaintiff's Complaint fails to state a cause of action and/or claim upon which relief may
be granted.
10. The occurrence alleged in Plaintiff's Complaint was unavoidable in nature and beyond the
control of Answering Defendant.
11. This action is barred by the Statute of Limitations.
12. Plaintiff assumed the risk inherent in the activity engaged in by Plaintiff.
13. The alleged injuries, damages, and losses are the result of an independent, supervening
agency or instrumentality over which Answering Defendants had no control.
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14. Plaintiff failed to exercise due care for his/her own safety under the circumstances.
15. This action is barred by the doctrine of avoidable consequences due to a failure to mitigate
damages.
16. Answering Defendant owed no duty to the Plaintiff.
17. Answering Defendant had no actual or constructive notice of the alleged dangerous
condition.
18. Pursuant to N.J.S.A. 2A:15-97, Defendants are entitled to a deduction from any award in
favor of Plaintiff of all amounts Plaintiff receives, or is entitled to receive, from any source other than a
joint tortfeasor.
19. Contrary to Rule 4:4-1 and Rule 4:37-2(a), Plaintiff did not cause the summons to issue
within 15 days of the filing of the Complaint; Defendants reserve the right to move to dismiss Plaintiff's
Complaint upon that ground.
20. The claims raised in the Plaintiff’s Complaint are barred on the grounds the product was
substantially altered after leaving the control of answering third party defendant.
21. The claims raised in Plaintiff’s Complaint are barred on the grounds the product was in a
condition which was reasonably safe for its intended use at the time it left the control of answering third
party defendant.
22. Answering Defendant asserts and incorporates herein by reference all defenses, exceptions
and exclusions available under the New Jersey Food and Drug Act, N.J.S.A. § 24:1-1, et seq.
23. Answering Defendant asserts and incorporates herein by reference all defenses, exceptions
and exclusions available under the New Jersey Uniform Commercial Code, N.J.S.A. § 12A:2-301, et seq.
24. Plaintiff’s injuries were the result of the alteration/modification of the product or products
in question.
25. This Answering Defendant asserts all defenses set forth in the New Jersey Product Liability
Act, N.J.S.A. 2A:58C-1 et seq.
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26. This Answering Defendant asserts that if, in fact, it manufactured and sold the product or
products in question, said product was reasonably fit, suitable and safe for its foreseeable uses when placed
in the stream of commerce.
27. Answering Defendant is not liable to Plaintiff(s) as the characteristics of the product were
known to the ordinary consumer or user, and any harm alleged was caused by some inherent characteristic
of the product which would be recognized by the ordinary person who uses or consumes the product with
ordinarily knowledge, to the of persons for whom the product was intended. N.J.S.A. 2A:58c-3(a)(2)
28. Answering Defendant was not the maker, manufacturer, owner, producer and/or packager
of the product in question.
29. There were adequate warnings or instructions on the product at issue.
RESERVATION OF DEFENSES AND OBJECTIONS
Defendant reserves the right to interpose such other defenses and objections as continuing
investigation may disclose.
CROSSCLAIM FOR CONTRIBUTION
TAKE NOTICE, Answering Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and
Cento Fine Foods, without admitting any liability herein, demands contribution from any and all Co-
defendants pursuant to the New Jersey Joint Tortfeasors Contribution Act.
CROSSCLAIM FOR INDEMNIFICATION
TAKE NOTICE, Answering Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and
Cento Fine Foods, without admitting any liability herein, assert that if they are found liable for Plaintiff’s
injuries and/or damages, such liability is only secondary, and that primary liability arose through the direct
and primary negligence and/or breach of contract of Co-defendants.
WHEREFORE, Answering Defendant demands judgment against Co-defendants, and
indemnification from them for all sums that may be found due against Answering Defendant in favor of the
Plaintiff.
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ANSWER TO CROSSCLAIMS AND COUNTERCLAIMS
Answering Defendant denies the allegations of any and all Crossclaims filed or to be filed by any
party to this action as they may relate to this defendant.
JURY DEMAND
Answering Defendant hereby demands a trial by jury as to all issues.
DEMAND FOR INTERROGATORY ANSWERS
Answering Defendant hereby demands that Plaintiff provide certified answers to Form A
Interrogatory questions and Codefendants provide answers to Form C and C4 Interrogatory questions as
set forth in Appendix II of the New Jersey Court Rules within the time frame provided in accordance with
R. 4:17-4.
DEMAND FOR SIGNED HIPPA AUTHORIZATIONS
Pursuant to R. 4:17-4(f), Answering Defendant hereby demand that Plaintiff provide individually
signed HIPPA authorizations for release of medical records for each and every health care provider named
in plaintiff’s answer to interrogatories.
CERTIFICATION OF OTHER ACTION OR PROCEEDING
I certify, pursuant to Rule 4:5-1 that, to the best of my knowledge, information and belief at this
time, the matter in controversy is not the subject matter of any other action pending in any Court nor of any
pending arbitration proceeding, that no other action or arbitration is contemplated, and further that there is
no other parties who could be joined in this action.
CERTIFICATION
The undersigned certifies that the within Answer is filed and served pursuant to R. 4:6, as extended.
LAW OFFICES OF
JAMES H. ROHLFING
Attorney for Defendant,
Alanric Food Distributors, Inc. d/b/a Ferrera
Foods and Cento Fine Foods
/s/ Gregory J. Guido
Dated: November 4, 2022 By: ______________________
Gregory J. Guido, Esq.
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LAW OFFICES OF JAMES H. ROHLFING 2022115901
By: Gregory J. Guido, Esquire – Attorney ID# 030442005
5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053
Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903
(856) 703-2130
(855) 857-9823 fax
Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods
: SUPERIOR COURT OF NEW JERSEY
LORI CARR, : LAW DIVISION
: OCEAN COUNTY
Plaintiff, :
v. : DOCKET NO. OCN-L-2045-22
:
:
ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION
D/B/A FERRERA FOODS AND CENTO FINE :
FOODS; MULBERRY STREET; JOHN DOES :
1-5; SALLY ROES 1-10; RICHARD ROES 1-5; :
ABC CORPORATIONS 1-5 & XYZ :
DISTRUBUTOR CORPORATIONS 1-5, :
:
Defendants. :
:
:
SUPPLEMENTAL INTERROGATORIES TO PLAINTIFF
1. If you were involved in any prior or subsequent accidents and sought medical attention in
connection with said accident, set forth the date and a detailed description of the accident.
2. With regard to any accidents identified in the previous interrogatory, set forth a description of the
nature, extent and duration of any and all injuries.
3. If treated by any health care provider(s) in connection with any prior or subsequent accident
(including, but not limited to, hospitals, physicians or diagnostic testing facilities), state the name
and present address of each provider and provide a HIPAA compliant authorization pursuant R.
4:17-4(f) in the form annexed hereto.
4. If you have ever been a plaintiff in a lawsuit for personal injuries, identify the venue and docket
number of said lawsuit.
5. State the names and present addresses of plaintiff’s family doctor or primary care physician for
the past ten (10) years and provide a HIPAA compliant authorization pursuant R. 4:17-4(f) in the
form annexed hereto.
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6. State the names and present addresses of any chiropractor, rheumatologist, orthopedist and/or
neurologist plaintiff treated with during the past ten (10) years and provide a HIPAA compliant
authorization pursuant R. 4:17-4(f) in the form annexed hereto.
7. Set forth the name of your health insurance carrier for the past 10 years.
8. Identify all social media platforms of which Plaintiff has been a member for the past 5 years.
9. For any social media platforms identified in the preceding request, list all handles, names and/or
usernames associated with each social media platform.
LAW OFFICES OF
JAMES H. ROHLFING
Attorney for Defendant,
Alanric Food Distributors, Inc. d/b/a Ferrera
Foods and Cento Fine Foods
/s/ Gregory J. Guido
Dated: November 4, 2022 By:
Gregory J. Guido, Esq.
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LAW OFFICES OF JAMES H. ROHLFING 2022115901
By: Gregory J. Guido, Esquire – Attorney ID# 030442005
5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053
Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903
(856) 703-2130
(855) 857-9823 fax
Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods
: SUPERIOR COURT OF NEW JERSEY
LORI CARR, : LAW DIVISION
: OCEAN COUNTY
Plaintiff, :
v. : DOCKET NO. OCN-L-2045-22
:
:
ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION
D/B/A FERRERA FOODS AND CENTO FINE :
FOODS; MULBERRY STREET; JOHN DOES : NOTICE TO PRODUCE TO PLAINTIFF
1-5; SALLY ROES 1-10; RICHARD ROES 1-5; :
ABC CORPORATIONS 1-5 & XYZ :
DISTRUBUTOR CORPORATIONS 1-5, :
:
Defendants. :
:
:
Pursuant to R. 4:18-1, we hereby request that you produce true and complete copies of the following
documents at the Law Offices of James H. Rohlfing, P.O. Box 2903, Hartford, CT 06104-2903, within the
time prescribed by the Rules of Court:
1. Any and all employment records, communications with any employers indicating that the plaintiff lost
wages or other profits or compensation as a result of the alleged negligence of the defendant herein.
2. Any and all x-rays, or CT scans or other diagnostic studies of any part of the body of plaintiff in the
possession of plaintiff or his/her attorney.
3. Any statement made by the defendant herein which is in the possession of plaintiff or his/her attorney.
4. True copies of any and all police, fire, rescue squad, ambulance or other governmental agency reports
regarding the occurrence of the alleged accident.
5. True and exact copies of any and all reports and/or correspondence provided by any experts who have
reviewed any aspect of this case on behalf of plaintiff or his/her attorney, including those provided by
experts whom the responding party does not intend to call as a witness.
6. True and exact copies of any insurance agreements or policies that may cover, indemnify or reimburse
plaintiff for any payments made in connection with the plaintiff’s damages, including, but not limited to,
payment of medical expenses incurred by a plaintiff in this case.
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7. True and exact copies of any and all documents you intend to utilize at trial for purposes of direct or
cross-examination of any witnesses or which you will seek to have introduced into evidence or otherwise
utilize to prove your case.
8. True and exact copies of the portion of any learned treatises intended to be used at the trial of this action.
9. Prints (at our expense) of any photographs taken by any party at the scene of the accident or incident or
that depict the scene or any of plaintiff’s injuries.
10. All hospital records and bills regarding a plaintiff including consultation notes, reports, x-ray notes, x-
rays, nurses’ notes, histories, laboratory tests, admission reports, discharge reports, and all other similar
documents relating to the accident and injuries referred to in the Complaint.
11. True copies of all physician reports and bills relating to the accident and injuries alleged in the
Complaint including, but not limited to, consultation notes and reports, x-ray notes and reports, and all
records pertaining to a plaintiff.
12. True copies of any and all statements, signed or unsigned, written or recorded, taken from or given by
the defendants, their agents, servants, employees or representatives, concerning any matter relevant to this
litigation.
13. All written communications, other than pleadings, signed or unsigned, between the plaintiff and the
defendants.
14. True copies of all reports filed or completed on behalf of the plaintiff regarding the occurrence of the
accident and submitted to any governmental agency, federal, state or local.
15. True copies of any and all reports of any and all experts with regard to the occurrence of the accident,
any alleged defects in the product in question, if applicable, or the nature and/or extent of the alleged injuries
or damages.
16. All statements, signed or unsigned, written or recorded, of any and all witnesses to the occurrence of
the alleged accident, to the alleged negligence of the defendants, to the activities of any of the parties during
the 12 hours immediately preceding the alleged accident and/or to the nature and extent of a plaintiff’s
alleged injuries and/or damages.
17. If any plaintiff in this action is acting in a representative capacity, i.e., guardian, administrator, etc.,
attach hereto true and exact copies of all documents which evidence the existence of such representative
capacity.
18. If a per quod claim is being made, attach hereto a true and exact copy of your marriage license.
19. True copies of each plaintiff’s state and federal income tax returns, including W-2 forms, for the two
(2) year period immediately prior to the year of the accident, the year of the accident, and the two (2) year
period after the year of the accident.
20. True copies of all records concerning any prior or subsequent personal injury claims or litigation,
including, but not limited to, all medical records, pleadings, deposition transcripts, interrogatory answers,
Releases, etc.
21. State whether you have applied for Social Security Disability benefits. If so, state when.
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22. State whether you were, or are, a Medicare beneficiary. If so, state:
a. Whether you are a Medicare beneficiary at the time of the alleged occurrence in your complaint;
b. Whether you are currently receiving Medicare benefits;
c. Provide the Medicare number and identify amounts paid by Medicare for the treatment claimed
as a result of the alleged occurrence described in Plaintiff’s Complaint; and identify any and all
communications with Medicare with respect to any payments made.
23. Please provide all documentation in your possession and control with regards to Medicare’s
involvement or right to recovery in this claim, including but not limited to, Medicare’s payment letter or
lien notification.
24. If any plaintiff, or plaintiff’s attorney, or anyone on their behalf, has entered into an agreement, contract,
contingency, or loan with a lender, litigation funding company, litigation lending company, medical funding
company or other similar entity, company, corporation, partnership or person that is engaged in loaning
money, advancing money or financially assisting you or your attorney in any aspect of this case, whether it
be for payment of medical bills, litigation expenses, witness expenses, lost wages or an advancement against
a portion or all of any potential recovery you may receive, please produce the following:
a. The complete name and address of the lender, litigation funding company, litigation lending
company, medical funding company or similar entity as described above;
b. The date on which agreement, advance or loan was made;
c. The amount of such agreement, advance or loan;
d. All information, including documents of any kind provided to the lender, litigation funding
company, litigation lending company, either pursuant to the request of the litigation funding
company, litigation lending company, or voluntarily.
25. Please provide legible copies of all brochures, applications, contracts, agreements, liens,
correspondence or other similar documents received and/or completed by any plaintiff or plaintiff’s attorney
as part of the process of entering into all agreements, negotiations and contracts with a lender, litigation
funding company, litigation lending company, medical funding company, or similar entity.
26. A complete and accurate list with current addresses of all doctors, physicians, hospitals, health care
facilities, health care providers, and/or therapists who have evaluated, examined and/or treated plaintiff in
the past fifteen (15) years for any reason.
LAW OFFICES OF
JAMES H. ROHLFING
Attorney for Defendant,
Alanric Food Distributors, Inc. d/b/a Ferrera
Foods and Cento Fine Foods
/s/ Gregory J. Guido
Dated: November 4, 2022 By:
Gregory J. Guido, Esq.
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Civil Case Information Statement
Case Details: OCEAN | Civil Part Docket# L-002045-22
Case Caption: CARR LORI VS ALANRIC FOOD DISTRIB Case Type: PRODUCT LIABILITY
UTORS, IN Document Type: Answer W/CrossClaim W/Jury Demand
Case Initiation Date: 09/15/2022 Jury Demand: YES - 6 JURORS
Attorney Name: GREGORY J GUIDO Is this a professional malpractice case? NO
Firm Name: TRAVELERS INSURANCE CO Related cases pending: NO
Address: 5 GREENTREE CTR STE 407 525 RT 73 N If yes, list docket numbers:
MARLTON NJ 080533426 Do you anticipate adding any parties (arising out of same
Phone: 8567032130 transaction or occurrence)? NO
Name of Party: DEFENDANT : ALANRIC FOOD Does this case involve claims related to COVID-19? NO
DISTRIBUTORS, INC
Name of Defendant’s Primary Insurance Company Are sexual abuse claims alleged by: LORI CARR? NO
(if known): Travelers
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)
11/04/2022 /s/ GREGORY J GUIDO
Dated Signed
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Preview
OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 1 of 13 Trans ID: LCV20223865229 LAW OFFICES OF JAMES H. ROHLFING 2022115901 By: Gregory J. Guido, Esquire – Attorney ID# 030442005 5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053 Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903 (856) 703-2130 (855) 857-9823 fax Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods : SUPERIOR COURT OF NEW JERSEY LORI CARR, : LAW DIVISION : OCEAN COUNTY Plaintiff, : v. : DOCKET NO. OCN-L-2045-22 : : ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION D/B/A FERRERA FOODS AND CENTO FINE : FOODS; MULBERRY STREET; JOHN DOES : ANSWER TO PLAINTIFFS’ COMPLAINT, 1-5; SALLY ROES 1-10; RICHARD ROES 1-5; : SEPARATE DEFENSES, CROSSCLAIMS, ABC CORPORATIONS 1-5 & XYZ : DEMAND FOR JURY TRIAL, DEMAND DISTRUBUTOR CORPORATIONS 1-5, : FOR INTERROGATORIES, : CERTIFICATIONS Defendants. : : : Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods, by way of answer to the Complaint, says: 1. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 1, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 2. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 3. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 3, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 2 of 13 Trans ID: LCV20223865229 4. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 5. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 6. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 7. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 7, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 8. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 8, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 9. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 10. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 10, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 11. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 11, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 3 of 13 Trans ID: LCV20223865229 WHEREFORE, Defendant Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods demands judgment in its favor dismissing this Count of the Complaint and awarding costs. FIRST COUNT 1. Repeated allegations are answered as heretofore. 2. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. 3. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 4. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 5. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 6. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 7. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. 8. The allegations of this Paragraph are not directed at Answering Defendant, therefore, no answer is made thereto, and strict proof thereof is demanded at the time of Trial, if relevant and related to Answering Defendant. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 4 of 13 Trans ID: LCV20223865229 9. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 9, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint and awarding costs. SECOND COUNT 1. Repeated allegations are answered as heretofore. 2. Answering Defendant is without information or knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 2, therefore, no Answer is made to said allegations and strict proof thereof is demanded at the time of Trial. Answering Defendant is not the manufacturer of any such product as alleged in this Paragraph. Upon information and belief, the manufacturer is situated in the country of Italy. 3. Denied. 4. Denied. 5. Denied. 6. Denied. 7. Denied. 8. Denied. WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint and awarding costs. THIRD COUNT 1. Repeated allegations are answered as heretofore. 2. Denied as to Answering Defendant. 3. Denied as to Answering Defendant. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 5 of 13 Trans ID: LCV20223865229 WHEREFORE, Defendant demands judgment in its favor dismissing this Count of the Complaint and awarding costs. SEPARATE DEFENSES 1. Answering Defendant performed each and every duty and obligation owed to Plaintiff. 2. Answering Defendant acted reasonably under all of the circumstances. 3. Answering Defendant did not commit any negligence which was the proximate cause of the injuries alleged. 4. Any injuries and/or damages allegedly sustained by Plaintiff were the result of the negligence and/or contributory negligence of said Plaintiff. 5. Plaintiff is barred from recovery by contributory negligence, which negligence was greater than that of Answering Defendant. 6. Plaintiff's claim against Answering Defendant is eliminated and/or reduced by the applicable provisions of the New Jersey Comparative Negligence Act, N.J.S.A. 2A:15-5.1 et seq. 7. Defendants are not liable for more than its proper percentage of any award, as set forth in N.J.S.A. 2A:15-5.1 et seq. 8. Any injuries and/or damages allegedly sustained by Plaintiff were the result of the sole negligence and/or contributory negligence of a third party or parties over whom Answering Defendants had no control or right of control. 9. Plaintiff's Complaint fails to state a cause of action and/or claim upon which relief may be granted. 10. The occurrence alleged in Plaintiff's Complaint was unavoidable in nature and beyond the control of Answering Defendant. 11. This action is barred by the Statute of Limitations. 12. Plaintiff assumed the risk inherent in the activity engaged in by Plaintiff. 13. The alleged injuries, damages, and losses are the result of an independent, supervening agency or instrumentality over which Answering Defendants had no control. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 6 of 13 Trans ID: LCV20223865229 14. Plaintiff failed to exercise due care for his/her own safety under the circumstances. 15. This action is barred by the doctrine of avoidable consequences due to a failure to mitigate damages. 16. Answering Defendant owed no duty to the Plaintiff. 17. Answering Defendant had no actual or constructive notice of the alleged dangerous condition. 18. Pursuant to N.J.S.A. 2A:15-97, Defendants are entitled to a deduction from any award in favor of Plaintiff of all amounts Plaintiff receives, or is entitled to receive, from any source other than a joint tortfeasor. 19. Contrary to Rule 4:4-1 and Rule 4:37-2(a), Plaintiff did not cause the summons to issue within 15 days of the filing of the Complaint; Defendants reserve the right to move to dismiss Plaintiff's Complaint upon that ground. 20. The claims raised in the Plaintiff’s Complaint are barred on the grounds the product was substantially altered after leaving the control of answering third party defendant. 21. The claims raised in Plaintiff’s Complaint are barred on the grounds the product was in a condition which was reasonably safe for its intended use at the time it left the control of answering third party defendant. 22. Answering Defendant asserts and incorporates herein by reference all defenses, exceptions and exclusions available under the New Jersey Food and Drug Act, N.J.S.A. § 24:1-1, et seq. 23. Answering Defendant asserts and incorporates herein by reference all defenses, exceptions and exclusions available under the New Jersey Uniform Commercial Code, N.J.S.A. § 12A:2-301, et seq. 24. Plaintiff’s injuries were the result of the alteration/modification of the product or products in question. 25. This Answering Defendant asserts all defenses set forth in the New Jersey Product Liability Act, N.J.S.A. 2A:58C-1 et seq. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 7 of 13 Trans ID: LCV20223865229 26. This Answering Defendant asserts that if, in fact, it manufactured and sold the product or products in question, said product was reasonably fit, suitable and safe for its foreseeable uses when placed in the stream of commerce. 27. Answering Defendant is not liable to Plaintiff(s) as the characteristics of the product were known to the ordinary consumer or user, and any harm alleged was caused by some inherent characteristic of the product which would be recognized by the ordinary person who uses or consumes the product with ordinarily knowledge, to the of persons for whom the product was intended. N.J.S.A. 2A:58c-3(a)(2) 28. Answering Defendant was not the maker, manufacturer, owner, producer and/or packager of the product in question. 29. There were adequate warnings or instructions on the product at issue. RESERVATION OF DEFENSES AND OBJECTIONS Defendant reserves the right to interpose such other defenses and objections as continuing investigation may disclose. CROSSCLAIM FOR CONTRIBUTION TAKE NOTICE, Answering Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods, without admitting any liability herein, demands contribution from any and all Co- defendants pursuant to the New Jersey Joint Tortfeasors Contribution Act. CROSSCLAIM FOR INDEMNIFICATION TAKE NOTICE, Answering Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods, without admitting any liability herein, assert that if they are found liable for Plaintiff’s injuries and/or damages, such liability is only secondary, and that primary liability arose through the direct and primary negligence and/or breach of contract of Co-defendants. WHEREFORE, Answering Defendant demands judgment against Co-defendants, and indemnification from them for all sums that may be found due against Answering Defendant in favor of the Plaintiff. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 8 of 13 Trans ID: LCV20223865229 ANSWER TO CROSSCLAIMS AND COUNTERCLAIMS Answering Defendant denies the allegations of any and all Crossclaims filed or to be filed by any party to this action as they may relate to this defendant. JURY DEMAND Answering Defendant hereby demands a trial by jury as to all issues. DEMAND FOR INTERROGATORY ANSWERS Answering Defendant hereby demands that Plaintiff provide certified answers to Form A Interrogatory questions and Codefendants provide answers to Form C and C4 Interrogatory questions as set forth in Appendix II of the New Jersey Court Rules within the time frame provided in accordance with R. 4:17-4. DEMAND FOR SIGNED HIPPA AUTHORIZATIONS Pursuant to R. 4:17-4(f), Answering Defendant hereby demand that Plaintiff provide individually signed HIPPA authorizations for release of medical records for each and every health care provider named in plaintiff’s answer to interrogatories. CERTIFICATION OF OTHER ACTION OR PROCEEDING I certify, pursuant to Rule 4:5-1 that, to the best of my knowledge, information and belief at this time, the matter in controversy is not the subject matter of any other action pending in any Court nor of any pending arbitration proceeding, that no other action or arbitration is contemplated, and further that there is no other parties who could be joined in this action. CERTIFICATION The undersigned certifies that the within Answer is filed and served pursuant to R. 4:6, as extended. LAW OFFICES OF JAMES H. ROHLFING Attorney for Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods /s/ Gregory J. Guido Dated: November 4, 2022 By: ______________________ Gregory J. Guido, Esq. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 9 of 13 Trans ID: LCV20223865229 LAW OFFICES OF JAMES H. ROHLFING 2022115901 By: Gregory J. Guido, Esquire – Attorney ID# 030442005 5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053 Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903 (856) 703-2130 (855) 857-9823 fax Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods : SUPERIOR COURT OF NEW JERSEY LORI CARR, : LAW DIVISION : OCEAN COUNTY Plaintiff, : v. : DOCKET NO. OCN-L-2045-22 : : ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION D/B/A FERRERA FOODS AND CENTO FINE : FOODS; MULBERRY STREET; JOHN DOES : 1-5; SALLY ROES 1-10; RICHARD ROES 1-5; : ABC CORPORATIONS 1-5 & XYZ : DISTRUBUTOR CORPORATIONS 1-5, : : Defendants. : : : SUPPLEMENTAL INTERROGATORIES TO PLAINTIFF 1. If you were involved in any prior or subsequent accidents and sought medical attention in connection with said accident, set forth the date and a detailed description of the accident. 2. With regard to any accidents identified in the previous interrogatory, set forth a description of the nature, extent and duration of any and all injuries. 3. If treated by any health care provider(s) in connection with any prior or subsequent accident (including, but not limited to, hospitals, physicians or diagnostic testing facilities), state the name and present address of each provider and provide a HIPAA compliant authorization pursuant R. 4:17-4(f) in the form annexed hereto. 4. If you have ever been a plaintiff in a lawsuit for personal injuries, identify the venue and docket number of said lawsuit. 5. State the names and present addresses of plaintiff’s family doctor or primary care physician for the past ten (10) years and provide a HIPAA compliant authorization pursuant R. 4:17-4(f) in the form annexed hereto. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 10 of 13 Trans ID: LCV20223865229 6. State the names and present addresses of any chiropractor, rheumatologist, orthopedist and/or neurologist plaintiff treated with during the past ten (10) years and provide a HIPAA compliant authorization pursuant R. 4:17-4(f) in the form annexed hereto. 7. Set forth the name of your health insurance carrier for the past 10 years. 8. Identify all social media platforms of which Plaintiff has been a member for the past 5 years. 9. For any social media platforms identified in the preceding request, list all handles, names and/or usernames associated with each social media platform. LAW OFFICES OF JAMES H. ROHLFING Attorney for Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods /s/ Gregory J. Guido Dated: November 4, 2022 By: Gregory J. Guido, Esq. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 11 of 13 Trans ID: LCV20223865229 LAW OFFICES OF JAMES H. ROHLFING 2022115901 By: Gregory J. Guido, Esquire – Attorney ID# 030442005 5 Greentree Center , 525 Route 73 North, Suite 407, Marlton, NJ 08053 Mailing Address: P.O. Box 2903, Hartford, CT 06104-2903 (856) 703-2130 (855) 857-9823 fax Attorney for Defendants, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods : SUPERIOR COURT OF NEW JERSEY LORI CARR, : LAW DIVISION : OCEAN COUNTY Plaintiff, : v. : DOCKET NO. OCN-L-2045-22 : : ALANRIC FOOD DISTRIBUTORS, INC., : CIVIL ACTION D/B/A FERRERA FOODS AND CENTO FINE : FOODS; MULBERRY STREET; JOHN DOES : NOTICE TO PRODUCE TO PLAINTIFF 1-5; SALLY ROES 1-10; RICHARD ROES 1-5; : ABC CORPORATIONS 1-5 & XYZ : DISTRUBUTOR CORPORATIONS 1-5, : : Defendants. : : : Pursuant to R. 4:18-1, we hereby request that you produce true and complete copies of the following documents at the Law Offices of James H. Rohlfing, P.O. Box 2903, Hartford, CT 06104-2903, within the time prescribed by the Rules of Court: 1. Any and all employment records, communications with any employers indicating that the plaintiff lost wages or other profits or compensation as a result of the alleged negligence of the defendant herein. 2. Any and all x-rays, or CT scans or other diagnostic studies of any part of the body of plaintiff in the possession of plaintiff or his/her attorney. 3. Any statement made by the defendant herein which is in the possession of plaintiff or his/her attorney. 4. True copies of any and all police, fire, rescue squad, ambulance or other governmental agency reports regarding the occurrence of the alleged accident. 5. True and exact copies of any and all reports and/or correspondence provided by any experts who have reviewed any aspect of this case on behalf of plaintiff or his/her attorney, including those provided by experts whom the responding party does not intend to call as a witness. 6. True and exact copies of any insurance agreements or policies that may cover, indemnify or reimburse plaintiff for any payments made in connection with the plaintiff’s damages, including, but not limited to, payment of medical expenses incurred by a plaintiff in this case. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 12 of 13 Trans ID: LCV20223865229 7. True and exact copies of any and all documents you intend to utilize at trial for purposes of direct or cross-examination of any witnesses or which you will seek to have introduced into evidence or otherwise utilize to prove your case. 8. True and exact copies of the portion of any learned treatises intended to be used at the trial of this action. 9. Prints (at our expense) of any photographs taken by any party at the scene of the accident or incident or that depict the scene or any of plaintiff’s injuries. 10. All hospital records and bills regarding a plaintiff including consultation notes, reports, x-ray notes, x- rays, nurses’ notes, histories, laboratory tests, admission reports, discharge reports, and all other similar documents relating to the accident and injuries referred to in the Complaint. 11. True copies of all physician reports and bills relating to the accident and injuries alleged in the Complaint including, but not limited to, consultation notes and reports, x-ray notes and reports, and all records pertaining to a plaintiff. 12. True copies of any and all statements, signed or unsigned, written or recorded, taken from or given by the defendants, their agents, servants, employees or representatives, concerning any matter relevant to this litigation. 13. All written communications, other than pleadings, signed or unsigned, between the plaintiff and the defendants. 14. True copies of all reports filed or completed on behalf of the plaintiff regarding the occurrence of the accident and submitted to any governmental agency, federal, state or local. 15. True copies of any and all reports of any and all experts with regard to the occurrence of the accident, any alleged defects in the product in question, if applicable, or the nature and/or extent of the alleged injuries or damages. 16. All statements, signed or unsigned, written or recorded, of any and all witnesses to the occurrence of the alleged accident, to the alleged negligence of the defendants, to the activities of any of the parties during the 12 hours immediately preceding the alleged accident and/or to the nature and extent of a plaintiff’s alleged injuries and/or damages. 17. If any plaintiff in this action is acting in a representative capacity, i.e., guardian, administrator, etc., attach hereto true and exact copies of all documents which evidence the existence of such representative capacity. 18. If a per quod claim is being made, attach hereto a true and exact copy of your marriage license. 19. True copies of each plaintiff’s state and federal income tax returns, including W-2 forms, for the two (2) year period immediately prior to the year of the accident, the year of the accident, and the two (2) year period after the year of the accident. 20. True copies of all records concerning any prior or subsequent personal injury claims or litigation, including, but not limited to, all medical records, pleadings, deposition transcripts, interrogatory answers, Releases, etc. 21. State whether you have applied for Social Security Disability benefits. If so, state when. OCN-L-002045-22 11/04/2022 1:44:27 PM Pg 13 of 13 Trans ID: LCV20223865229 22. State whether you were, or are, a Medicare beneficiary. If so, state: a. Whether you are a Medicare beneficiary at the time of the alleged occurrence in your complaint; b. Whether you are currently receiving Medicare benefits; c. Provide the Medicare number and identify amounts paid by Medicare for the treatment claimed as a result of the alleged occurrence described in Plaintiff’s Complaint; and identify any and all communications with Medicare with respect to any payments made. 23. Please provide all documentation in your possession and control with regards to Medicare’s involvement or right to recovery in this claim, including but not limited to, Medicare’s payment letter or lien notification. 24. If any plaintiff, or plaintiff’s attorney, or anyone on their behalf, has entered into an agreement, contract, contingency, or loan with a lender, litigation funding company, litigation lending company, medical funding company or other similar entity, company, corporation, partnership or person that is engaged in loaning money, advancing money or financially assisting you or your attorney in any aspect of this case, whether it be for payment of medical bills, litigation expenses, witness expenses, lost wages or an advancement against a portion or all of any potential recovery you may receive, please produce the following: a. The complete name and address of the lender, litigation funding company, litigation lending company, medical funding company or similar entity as described above; b. The date on which agreement, advance or loan was made; c. The amount of such agreement, advance or loan; d. All information, including documents of any kind provided to the lender, litigation funding company, litigation lending company, either pursuant to the request of the litigation funding company, litigation lending company, or voluntarily. 25. Please provide legible copies of all brochures, applications, contracts, agreements, liens, correspondence or other similar documents received and/or completed by any plaintiff or plaintiff’s attorney as part of the process of entering into all agreements, negotiations and contracts with a lender, litigation funding company, litigation lending company, medical funding company, or similar entity. 26. A complete and accurate list with current addresses of all doctors, physicians, hospitals, health care facilities, health care providers, and/or therapists who have evaluated, examined and/or treated plaintiff in the past fifteen (15) years for any reason. LAW OFFICES OF JAMES H. ROHLFING Attorney for Defendant, Alanric Food Distributors, Inc. d/b/a Ferrera Foods and Cento Fine Foods /s/ Gregory J. Guido Dated: November 4, 2022 By: Gregory J. Guido, Esq. OCN-L-002045-22 11/04/2022 OCN-L-002045-22 11/04/20221:44:27 1:44:23PM PM Pg 1 of 2 Trans TransID: ID:LCV20223865229 LCV20223865229 Civil Case Information Statement Case Details: OCEAN | Civil Part Docket# L-002045-22 Case Caption: CARR LORI VS ALANRIC FOOD DISTRIB Case Type: PRODUCT LIABILITY UTORS, IN Document Type: Answer W/CrossClaim W/Jury Demand Case Initiation Date: 09/15/2022 Jury Demand: YES - 6 JURORS Attorney Name: GREGORY J GUIDO Is this a professional malpractice case? NO Firm Name: TRAVELERS INSURANCE CO Related cases pending: NO Address: 5 GREENTREE CTR STE 407 525 RT 73 N If yes, list docket numbers: MARLTON NJ 080533426 Do you anticipate adding any parties (arising out of same Phone: 8567032130 transaction or occurrence)? NO Name of Party: DEFENDANT : ALANRIC FOOD Does this case involve claims related to COVID-19? NO DISTRIBUTORS, INC Name of Defendant’s Primary Insurance Company Are sexual abuse claims alleged by: LORI CARR? NO (if known): Travelers 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) 11/04/2022 /s/ GREGORY J GUIDO Dated Signed OCN-L-002045-22 11/04/2022 OCN-L-002045-22 11/04/20221:44:27 1:44:23PM PM Pg 2 of 2 Trans TransID: ID:LCV20223865229 LCV20223865229