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Appendix XII-B1
CIVIL CASE INFORMATION STATEMENT
(CIS)
Use for initial Law Division - Civil Part pleadings (not PAYMENT TYPE: CK CG CA
motions) under Rule 4:5-1. CHG / CK NO.
Pleading will be rejected for filing, under Rule 1:5-6( c ), AMOUNT:
if information above the black bar is not completed or OVERPAYMENT:
if attorney's signature is not affixed. BATCH NUMBER:
ATTORNEY/ PRO SE NAME TELEPHONE NUMBER COUNTY OF VENUE:
Ada Gallicchio, Esq. 856-596-7778 OCEAN
FIRM NAME: DOCKET NUMBER (When available)
LAW OFFICE OF ALPHONSO H. IBRAHIM OCN-L-2045-22
OFFICE ADDRESS DOCUMENT TYPE
PO Box 6835 ANSWER, CROSSCLAIMS &
Scranton, PA 18505-6835 DEMANDS
JURY DEMAND
__ X__ YES _____ NO
NAME OF PARTY (e.g. John Doe, Plaintiff) CAPTION
Mulberry Street Italian Food Center Inc CARR vs. MULBERRY STREET, et al.
T/A Mulberry Street
CASE TYPE HURRICANE IS THIS A PROFESSIONAL MALPRACTICE CASE? ___YES __X__NO
NUMBER (See reverse side SANDY
for listing) RELATED? IF YOU HAVE CHECKED “YES” SEE N.J.S.A 2A::53A-27 AND APPLICABLE
605 CASE LAW REGARDING YOUR OBLIGATION TO FILE AFFIDAVIT OF
___YES _X__NO MERIT.
RELATED CASES IF YES, LIST DOCKET NUMBERS:
PENDING? _______YES ___X___ NO
NAME OF DEFENDANT’S PRIMARY INSURANCE COMPANY, IF KNOWN:
Liberty Mutual Insurance Company __ __ NONE _____ UNKNOWN
DO YOU ANTICIPATE ADDING ANY PARTIES (arising out of same transaction or occurrence)?
______YES ______ NO Unknown at this time
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE.
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
A. DO PARTIES HAVE A CURRENT, PAST OR RECURRENT RELATIONSHIP? ? _____YES ___X___ NO
IF YES, IS THAT
_______EMPLOYER-EMPLOYEE ________FRIEND/ NEIGHBOR ______OTHER(explain) ________FAMILIAL
________BUSINESS RELATIONSHIP
B. DOES THE STATUTE GOVERNING THIS CASE PROVIDE FOR PAYMENT OF FEES BY
THE LOSING PARTY? ________ YES __X__ 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? ______YES NO
UNKNOWN AT THIS TIME
IF YES, PLEASE IDENTIFY THE REQUESTED ACCOMMODATION:__________________________
WILL AN INTERPRETER BE NEEDED? UNKNOWN AT THIS TIME
______ YES NO IF YES, FOR WHAT LANGUAGE:____________________________
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).
ATTORNEY SIGNATURE
Ada Gallicchio, Esq.
Effective 06/05/2017, CN 10517
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CIVIL CASE INFORMATION STATEMENT
(CIS)
Use for initial pleadings (not motions) under Rule 4:5-1
CASE TYPES (Choose one and enter number of case type in appropriate space on the reverse side.)
Track 1 - 150 days' discovery
151 NAME CHANGE
175 FORFEITURE
302 TENANCY
399 REAL PROPERTY (other than Tenancy, Contract, Condemnation, Complex Commercial or Construction)
502 BOOK ACCOUNT (debt collection matters only)
505 OTHER INSURANCE CLAIM (INCLUDING DECLARATORY JUDGMENT ACTIONS)
506 PIP COVERAGE
510 UM or UIM CLAIM
511 ACTION ON NEGOTIABLE INSTRUMENT
512 LEMON LAW
801 SUMMARY ACTION
802 OPEN PUBLIC RECORDS ACT (SUMMARY ACTION)
999 OTHER (Briefly described nature of action)
Track 11 - 300 days' discovery
305 CONSTRUCTION
509 EMPLOYMENT (other than CEPA or LAD)
599 CONTRACT/COMMERCIAL TRANSACTION
603N AUTO NEGLIGENCE – PERSONAL INJURY (non-verbal threshold)
603Y AUTO NEGLIGENCE - PERSONAL INJURY (verbal threshold)
605 PERSONAL INJURY
610 AUTO NEGLIGENCE - PROPERTY DAMAGE
621 UM or UIM CLAIM (includes bodily injury)
699 TORT-OTHER
Track III - 450 days' discovery
005 CIVIL RIGHTS
301 CONDEMNATION
602 ASSAULT AND BATTERY
604 MEDICAL MALPRACTICE
606 PRODUCT LIABILITY
607 PROFESSIONAL MALPRACTICE
608 TOXIC TORT
609 DEFAMATION
616 WHISTLEBLOWER / CONSCIENTIOUS EMPLOYEE PROTECTION ACT (CEPA) CASES
617 INVERSE CONDEMNATION
618 LAW AGAINST DISCRIMINATION (LAD) CASES
Track IV - Active Case Management by Individual Judge/ 450 days' discovery
156 ENVIRONMENTAL/ENVIRONMENTAL COVERAGE LITIGATION
303 MT. LAUREL
508 COMPLEX COMMERCIAL
513 COMPLEX CONSTRUCTION
514 INSURANCE FRAUD
620 FALSE CLAIMS ACT
701 ACTIONS IN LIEU OF PREROGATIVE WRITS
Multicounty Litigation (Track IV)
271 ACCUTANE/ISOTRETINOIN 292 PELVIC MESH/BARD
274 RISPERDAL/SEROQUEL/ZYPREXA 293 DEPUY ASR HIP IMPLANT LITIGATION
281 BRISTOL-MYERS SQUIBB ENVIRONMENTAL 295 ALLODERM REGENERATIVE TISSUE MATRIX
282 FOSAMAX 296 STRYKER REJUVENATE/ABG II MODULAR HIP STEM COMPONENTS
285 STRYKER TRIDENT HIP IMPLANTS 297 MIRENA CONTRACEPTIVE MEDICATIONS/BENICAR
286 LEVAQUIN 299 OLMENSARTAN MEDOXOMIL MEDICATIONS/BENICAR
287 YAZ/YASMIN/OCELLA 300 TALC-BASED BODY POWDERS
289 REGLAN 601 ASBESTOS
290 POMPTON LAKES ENVIRONMENTAL LITIGATION 623 PRPECIA
291 PELVIC MESH/GYNECARE 624 STRYKER LFIT CoCr V40 FEMORAL HEADS
If you believe this case requires a track other than that provided above, please indicate the reason on side 1, in the space under "Case
Characteristics."
Please check off each applicable category: ___Punitive Class Action __Title 59
Effective 06/05/2017, CN 10517
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Law Office of Alphonso H. Ibrahim
BY: Ada Gallicchio, Esq.
Attorney ID#: 015692000
PO Box 6835
Scranton, PA 18505-6835
856-596-7778
Attorneys for Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street
Plaintiff: SUPERIOR COURT OF NEW JERSEY
LORI CARR, LAW DIVISION: OCEAN CO.
DOCKET NO.: OCN-L-2045-22
vs. *
CIVIL ACTION
Defendants: *
ALANRIC FOOD DISTRIBUTORS, INC. ANSWER, CROSSCLAIMS & DEMANDS
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 DISTRIBUTOR CORPORATIONS 1-5.
Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, by way of
Answer to the Complaint filed in the within matter, says:
THE PARTIES AND RELEVANT FACTS
1. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
3. Answering Defendant(s) admit(s) the allegations contained in paragraph.
4. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
5. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
6. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
7. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
8. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
9. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
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form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
10. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
11. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry
Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever.
FIRST COUNT
1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street,
hereby incorporates by reference the answers to all paragraphs contained the First Count, as though
same were fully set forth herein at length.
2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry
Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever.
SECOND COUNT
1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street,
hereby incorporates by reference the answers to all paragraphs contained the First Count, as though
same were fully set forth herein at length.
2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
3. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
4. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
5. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
6. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
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form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
7. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
8. Answering Defendant(s) is/are without sufficient knowledge or information upon which to
form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s).
WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry
Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever.
THIRD COUNT
1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street,
hereby incorporates by reference the answers to all paragraphs contained the First Count, as though
same were fully set forth herein at length.
2. Denied as to Answering Defendant(s).
3. Denied as to Answering Defendant(s).
WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry
Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever.
FIRST AFFIRMATIVE DEFENSE
Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, was
not negligent.
SECOND AFFIRMATIVE DEFENSE
The damages alleged were caused or contributed to by the negligence of the Plaintiff(s).
THIRD AFFIRMATIVE DEFENSE
Plaintiff(s) damages, if any, should be diminished by the percentage of negligence
attributable to the Plaintiff in accordance with the provisions of N.J.S.A., 2A:15-5.1
et seq.
FOURTH AFFIRMATIVE DEFENSE
The Defendant(s) denies violating any legal duty owed to the Plaintiff(s).
FIFTH AFFIRMATIVE DEFENSE
The damages alleged were the proximate result of the negligence of third parties over whom
this Defendant(s) had no control.
SIXTH AFFIRMATIVE DEFENSE
The damages alleged were the proximate result of the negligence of Co-Defendants over
whom this Defendant(s) had no control.
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SEVENTH AFFIRMATIVE DEFENSE
Plaintiffs’ Complaint fails to state a cause of action against this Defendant upon which relief
can be granted.
EIGHTH AFFIRMATIVE DEFENSE
The Plaintiff altered, modified and misused the product causing or contributing to the defect
alleged.
NINTH AFFIRMATIVE DEFENSE
Third parties altered, modified and misused the product causing or contributing to the defect
alleged.
TENTH AFFIRMATIVE DEFENSE
Co-Defendants altered, modified and misused the product causing or contributing to the
defect alleged.
ELEVENTH AFFIRMATIVE DEFENSE
This cause of action is barred by N.J.S.A. 2A:14-2.
TWELFTH AFFIRMATIVE DEFENSE
Answering Defendant’s liability is limited to the terms of an express warranty.
THIRTEENTH AFFIRMATIVE DEFENSE
The Plaintiff voluntarily and unreasonably encountered a known hazard thereby barring or
limiting recovery for the defect alleged.
FOURTEENTH AFFIRMATIVE DEFENSE
Plaintiff intentionally exposed himself to a known hazard with foreknowledge of the
probable results thereby barring or limiting the recovery for the defect alleged.
FIFTEENTH AFFIRMATIVE DEFENSE
Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, is not liable to
the Plaintiff(s) because the product in question (1) was reasonably fit, suitable and safe for its
intended purpose; (2) did not deviate from the design specifications, formula, or performance
standards of the manufacturer or from otherwise identical units manufactured to the same
manufacturing specifications or formula; (3) contained adequate warnings and instructions; and (4)
was not designed in a defective manner. N.J.S.A. 2A:58c-2.
SIXTEENTH AFFIRMATIVE DEFENSE
Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is not liable to
the Plaintiff(s) for any alleged design defect because at the time the product left its control, there
was not a practical and technically feasible design that would have prevented the harm without
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substantially impairing the reasonably anticipated or intended function of the product. N.J.S.A.
2A:58c-3(a)(1).
SEVENTEENTH AFFIRMATIVE DEFENSE
The product in question has or had usefulness, is not or was not egregiously unsafe or ultra-
hazardous, and the ordinary user or consumer can or could have reasonably been expected to have
knowledge of the product's risk. N.J.S.A. 2A:58c-3(b).
EIGHTEENTH AFFIRMATIVE DEFENSE
Answering Defendant is not liable to Plaintiff(s) for any alleged design defect because 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).
NINETEENTH AFFIRMATIVE DEFENSE
Any danger posed by the product in question cannot or could not have been feasibly
eliminated without impairing the usefulness of the product. N.J.S.A. 2A:58c-3(a)(2).
TWENTIETH AFFIRMATIVE DEFENSE
Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is
not liable to the Plaintiff(s) for any alleged design defect because the alleged harm was caused by an
unavoidably unsafe aspect of the product and the product was accompanies by an adequate warning
or instruction. N.J.S.A. 2A:58c-3(a)(3).
TWENTY-FIRST AFFIRMATIVE DEFENSE
Answering Defendant is not liable to Plaintiff(s) for any alleged harm caused by a failure to
warn because the product in question contains or contained an adequate warning or instruction.
N.J.S.A. 2A:58c-4.
TWENTY-SECOND AFFIRMATIVE DEFENSE
Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is
not liable to the Plaintiff(s) for any alleged harm caused by a failure to warn with respect to the
product because the warning or instruction provided, communicated or communicates adequate
information on the dangers and safe use of the product, taking into account the characteristics of,
and the ordinary knowledge common to, the persons by whom the product was intended to be used.
N.J.S.A. 2A:58c-4.
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CROSSCLAIM FOR CONTRIBUTION
While denying liability for damages to the Plaintiff(s), Lori Carr, should Defendant(s),
Mulberry Street Italian Food Center Inc T/A Mulberry Street be adjudged liable to the Plaintiff(s),
Answering Defendant(s) asserts that Co-Defendant(s) ALANRIC FOOD DISTRIBUTORS, INC.
D/B/A FERRERA FOODS AND CENTO FINE FOODS are joint tortfeasors and therefore,
Answering Defendant(s) demands contribution pursuant to the Joint Tortfeasor Act, N.J.S.A.
2A:53A-1, et seq., the Comparative Negligence Act of New Jersey, N.J.S.A., 2A:15-5.1 et seq. and
Rule 4:7-5.
CROSSCLAIM FOR INDEMNIFICATION
Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street,
asserts that he/she is entitled to be indemnified and saved harmless from all loss or liability
including attorneys fees and defense costs arising from the litigation by the Co-Defendant(s)
pursuant to common law and/or contract. Answering Defendant(s) further asserts that his/her
alleged wrongdoing, if any, was secondary, imputed and vicarious and that the alleged tortuous
wrongdoing, if any, of the Co-Defendant(s) was the primary, active and direct cause of the damages
alleged by the Plaintiff(s).
REPLY TO ALL CROSSCLAIMS
Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street,
denies that he/she is responsible for either indemnification or contribution to the Co-Defendant(s)
on any Crossclaim that is presently asserted against her or may be asserted against him/her.
NOTICE PURSUANT TO RULES 1:5-1(a) AND 4:17-4(c) AND 4:17-4(f)
TAKE NOTICE that the undersigned attorney, counsel for the Answering Defendant(s),
does hereby demand, pursuant to Rules 1:5-1(a) and 4:17-4(c) that each party herein serving
pleadings and Interrogatories and receiving answers thereto, serve copies of all such pleadings and
answered Interrogatories received from any party upon the undersigned attorney and TAKE
NOTICE that this is a continuing demand. Further, demand is made under Rule 4:17-4(f), whereby
a plaintiff or a counterclaimant in any action in which damages are sought for personal injuries shall
serve, contemporaneous with his or her answers to interrogatories, an executed form authorizing
disclosure to the opposing party or parties, for purposes of the litigation, of the plaintiff's or
counterclaimant's medical records pursuant to the Health Insurance Portability and Accountability
Act of 1996 (HIPAA), 42 U.S.C. §§ 1301 et seq., as to each health care provider named in his or her
answers to interrogatories excluding non-treating expert witnesses.
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DEMAND FOR WRITTEN STATEMENT OF DAMAGES CLAIMED
Demand is hereby made upon Plaintiff(s) to furnish within five (5) days of the receipt of this
Answer, a Written Statement of the Amount of Damages Claimed pursuant to Rule 4:5-2.
RESERVATION OF DEFENSES AND OBJECTIONS
This Defendant hereby reserves the right to interpose such other defenses and objections as
a continuing investigation may disclose.
DEMAND FOR A TRIAL BY JURY
Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, hereby
demands a trial by jury as to all the issues.
CERTIFICATION PURSUANT TO RULE 4:5-1
The matter in controversy is not the subject of any other known action pending in any
Court, or of a pending or contemplated arbitration proceeding. There are no other parties known
who should be joined in this action.
CERTIFICATION OF SERVICE
I hereby certify that a copy of the within pleading was served within the time prescribed by
Rule 4:6-1.
DESIGNATION OF TRIAL COUNSEL
PLEASE TAKE NOTICE that pursuant to Rule 4:25-4, Ada Gallicchio, Esq. is hereby
designated trial counsel.
Law Office of Alphonso H. Ibrahim
Attorney for Defendant(s),
Mulberry Street Italian Food Center Inc T/A
Mulberry Street
BY:
Ada Gallicchio, Esq.
DATED: October 21, 2022
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DEMAND FOR ANSWERS TO INTERROGATORIES
PLEASE TAKE NOTICE that the Answering Defendant(s) demands answers from the
Plaintiff(s) to Uniform Interrogatories, Form A and Supplemental Interrogatories, Demand for
Production of Documents as set forth in Appendix II of the New Jersey Court, and demands
answers from the Co- Defendant(s) to Uniform Interrogatories C and C1, as set forth in Appendix
II of the New Jersey Court and Demand for Documents.
Law Office of Alphonso H. Ibrahim
Attorney for Defendant(s),
Mulberry Street Italian Food Center Inc T/A
Mulberry Street
BY:
Ada Gallicchio, Esq.
DATED: October 21, 2022
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AUTHORIZATION TO DISCLOSE INDIVIDUALLY
IDENTIFIABLE HEALTH INFORMATION
PHOTOCOPY WILL BE ACCEPTED AS ORIGINAL
I, ___________________________________, hereby authorize the release of documents described below to:
Plaintiff Name
Recipient:
Liberty Mutual Insurance Company Law Office of Alphonso H. Ibrahim
Peerless Insurance Company 1 Executive Drive
Ohio Casualty OR Marlton Executive Park, 4th Floor
Safeco Insurance Company Marlton, NJ 08053
CASE NAME: CARR vs. MULBERRY STREET, et al.
Provider:
Patient Name: ___________________________________________________
Date of Birth:
Social Security #: XXX-XX-
To Whom It May Concern:
This authorizes the physicians, hospital and all medical attendants to furnish full and complete medical reports and information
requested. This authorization also pertains to examination of all medical records, hospital records, x-ray reports and films or
copies thereof, relating to examination, consultation, confinement or treatment, inclusive of care rendered for psychiatric, drug or
alcohol related disorders. This request is for the purpose of LITIGATION.
I understand that the terms of this authorization are governed by the health Insurance Portability and Accountability Act of 1996
and its implementing regulations (HIPAA). I understand that I have the right to revoke this authorization, at any time prior to the
compliance with the request set forth herein, provided that the revocation is in writing. I understand that my revocation must
include my name, address, telephone number, date of this authorization and my signature and that I should send it to:
Name and address of Provider
I understand that the information used or disclosed pursuant to this authorization may be subject to re-disclosure by the Recipient
and in that case, will no longer be protected by HIPAA.
I understand that if my medical records contain information related to the history, diagnosis and/ or treatment of any psychiatric
problems, mental illness, drug abuse, alcoholism, sexually transmitted or communicable disease, AIDS, or test for infection with
human immunodeficiency virus (HIV), that my signing this document authorized the above named provider to release that
information. I acknowledge and am aware that New Jersey has a statutory privilege accorded to confidential communications
between a patient and a licensed physician or psychologist and that my signing this form waives this privilege.
check here indicates that I believe my medical records may contain DNA test results or other genetic information. Such
information is specially protected by New Jersey law, and I will be contacted for separate, specific consent prior to release of this
information.
This authorization is being made voluntarily and expires upon release of the information described above or upon the completion
and resolution of the litigation, whichever comes first. I am willing that a photocopy of this authorization be accepted with the
same authority as the original.
Patient Signature:
(Plaintiff)
Patient Name: Date:
(Please print)
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AUTHORIZATION FOR EMPLOYMENT RECORDS
PHOTOCOPY WILL BE ACCEPTED AS AN ORIGINAL
TO:
RE: CARR vs. MULBERRY STREET, et al.
To Whom It May Concern:
I, ___________________________________, hereby request and authorize the release of
documents described below to:
Recipient:
Liberty Mutual Insurance Company Law Office of Alphonso H. Ibrahim
Peerless Insurance Company 1 Executive Drive
Ohio Casualty OR Marlton Executive Park, 4th Floor
Safeco Insurance Company Marlton, NJ 08053
Any or all records in your Personnel and/or Employment file regarding
_____________________________________ DOB:___________________, including
but not limited to employment application, employment physicals, worker's
compensation records, salary history, personnel reports, personnel evaluations, W-4
forms, and any or all records in your file.
SIGNATURE:
OCN-L-002045-22 10/21/2022
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9:31:18AM
AM Pg 1 of 1 Trans
TransID:
ID:LCV20223716999
LCV20223716999
Civil Case Information Statement
Case Details: OCEAN | Civil Part Docket# L-002045-22
Case Caption: CARR LORI VS ALANRIC FOOD DISTRIB Case Type: PERSONAL INJURY
UTORS, IN Document Type: Answer W/CrossClaim W/Jury Demand
Case Initiation Date: 09/15/2022 Jury Demand: YES - 6 JURORS
Attorney Name: ADA SACHTER GALLICCHIO Is this a professional malpractice case? NO
Firm Name: LIBERTY MUTUAL INSURANCE CO Related cases pending: NO
Address: PO BOX 6835 If yes, list docket numbers:
SCRANTON PA 185056835 Do you anticipate adding any parties (arising out of same
Phone: 8565967778 transaction or occurrence)? NO
Name of Party: DEFENDANT : MULBERRY STREET Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): LIBERTY MUTUAL INS CO Are sexual abuse claims alleged by: LORI CARR? 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)
10/21/2022 /s/ ADA SACHTER GALLICCHIO
Dated Signed
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OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 1 of 12 Trans ID: LCV20223716999 Appendix XII-B1 CIVIL CASE INFORMATION STATEMENT (CIS) Use for initial Law Division - Civil Part pleadings (not PAYMENT TYPE: CK CG CA motions) under Rule 4:5-1. CHG / CK NO. Pleading will be rejected for filing, under Rule 1:5-6( c ), AMOUNT: if information above the black bar is not completed or OVERPAYMENT: if attorney's signature is not affixed. BATCH NUMBER: ATTORNEY/ PRO SE NAME TELEPHONE NUMBER COUNTY OF VENUE: Ada Gallicchio, Esq. 856-596-7778 OCEAN FIRM NAME: DOCKET NUMBER (When available) LAW OFFICE OF ALPHONSO H. IBRAHIM OCN-L-2045-22 OFFICE ADDRESS DOCUMENT TYPE PO Box 6835 ANSWER, CROSSCLAIMS & Scranton, PA 18505-6835 DEMANDS JURY DEMAND __ X__ YES _____ NO NAME OF PARTY (e.g. John Doe, Plaintiff) CAPTION Mulberry Street Italian Food Center Inc CARR vs. MULBERRY STREET, et al. T/A Mulberry Street CASE TYPE HURRICANE IS THIS A PROFESSIONAL MALPRACTICE CASE? ___YES __X__NO NUMBER (See reverse side SANDY for listing) RELATED? IF YOU HAVE CHECKED “YES” SEE N.J.S.A 2A::53A-27 AND APPLICABLE 605 CASE LAW REGARDING YOUR OBLIGATION TO FILE AFFIDAVIT OF ___YES _X__NO MERIT. RELATED CASES IF YES, LIST DOCKET NUMBERS: PENDING? _______YES ___X___ NO NAME OF DEFENDANT’S PRIMARY INSURANCE COMPANY, IF KNOWN: Liberty Mutual Insurance Company __ __ NONE _____ UNKNOWN DO YOU ANTICIPATE ADDING ANY PARTIES (arising out of same transaction or occurrence)? ______YES ______ NO Unknown at this time THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE. CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION A. DO PARTIES HAVE A CURRENT, PAST OR RECURRENT RELATIONSHIP? ? _____YES ___X___ NO IF YES, IS THAT _______EMPLOYER-EMPLOYEE ________FRIEND/ NEIGHBOR ______OTHER(explain) ________FAMILIAL ________BUSINESS RELATIONSHIP B. DOES THE STATUTE GOVERNING THIS CASE PROVIDE FOR PAYMENT OF FEES BY THE LOSING PARTY? ________ YES __X__ 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? ______YES NO UNKNOWN AT THIS TIME IF YES, PLEASE IDENTIFY THE REQUESTED ACCOMMODATION:__________________________ WILL AN INTERPRETER BE NEEDED? UNKNOWN AT THIS TIME ______ YES NO IF YES, FOR WHAT LANGUAGE:____________________________ 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). ATTORNEY SIGNATURE Ada Gallicchio, Esq. Effective 06/05/2017, CN 10517 OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 2 of 12 Trans ID: LCV20223716999 CIVIL CASE INFORMATION STATEMENT (CIS) Use for initial pleadings (not motions) under Rule 4:5-1 CASE TYPES (Choose one and enter number of case type in appropriate space on the reverse side.) Track 1 - 150 days' discovery 151 NAME CHANGE 175 FORFEITURE 302 TENANCY 399 REAL PROPERTY (other than Tenancy, Contract, Condemnation, Complex Commercial or Construction) 502 BOOK ACCOUNT (debt collection matters only) 505 OTHER INSURANCE CLAIM (INCLUDING DECLARATORY JUDGMENT ACTIONS) 506 PIP COVERAGE 510 UM or UIM CLAIM 511 ACTION ON NEGOTIABLE INSTRUMENT 512 LEMON LAW 801 SUMMARY ACTION 802 OPEN PUBLIC RECORDS ACT (SUMMARY ACTION) 999 OTHER (Briefly described nature of action) Track 11 - 300 days' discovery 305 CONSTRUCTION 509 EMPLOYMENT (other than CEPA or LAD) 599 CONTRACT/COMMERCIAL TRANSACTION 603N AUTO NEGLIGENCE – PERSONAL INJURY (non-verbal threshold) 603Y AUTO NEGLIGENCE - PERSONAL INJURY (verbal threshold) 605 PERSONAL INJURY 610 AUTO NEGLIGENCE - PROPERTY DAMAGE 621 UM or UIM CLAIM (includes bodily injury) 699 TORT-OTHER Track III - 450 days' discovery 005 CIVIL RIGHTS 301 CONDEMNATION 602 ASSAULT AND BATTERY 604 MEDICAL MALPRACTICE 606 PRODUCT LIABILITY 607 PROFESSIONAL MALPRACTICE 608 TOXIC TORT 609 DEFAMATION 616 WHISTLEBLOWER / CONSCIENTIOUS EMPLOYEE PROTECTION ACT (CEPA) CASES 617 INVERSE CONDEMNATION 618 LAW AGAINST DISCRIMINATION (LAD) CASES Track IV - Active Case Management by Individual Judge/ 450 days' discovery 156 ENVIRONMENTAL/ENVIRONMENTAL COVERAGE LITIGATION 303 MT. LAUREL 508 COMPLEX COMMERCIAL 513 COMPLEX CONSTRUCTION 514 INSURANCE FRAUD 620 FALSE CLAIMS ACT 701 ACTIONS IN LIEU OF PREROGATIVE WRITS Multicounty Litigation (Track IV) 271 ACCUTANE/ISOTRETINOIN 292 PELVIC MESH/BARD 274 RISPERDAL/SEROQUEL/ZYPREXA 293 DEPUY ASR HIP IMPLANT LITIGATION 281 BRISTOL-MYERS SQUIBB ENVIRONMENTAL 295 ALLODERM REGENERATIVE TISSUE MATRIX 282 FOSAMAX 296 STRYKER REJUVENATE/ABG II MODULAR HIP STEM COMPONENTS 285 STRYKER TRIDENT HIP IMPLANTS 297 MIRENA CONTRACEPTIVE MEDICATIONS/BENICAR 286 LEVAQUIN 299 OLMENSARTAN MEDOXOMIL MEDICATIONS/BENICAR 287 YAZ/YASMIN/OCELLA 300 TALC-BASED BODY POWDERS 289 REGLAN 601 ASBESTOS 290 POMPTON LAKES ENVIRONMENTAL LITIGATION 623 PRPECIA 291 PELVIC MESH/GYNECARE 624 STRYKER LFIT CoCr V40 FEMORAL HEADS If you believe this case requires a track other than that provided above, please indicate the reason on side 1, in the space under "Case Characteristics." Please check off each applicable category: ___Punitive Class Action __Title 59 Effective 06/05/2017, CN 10517 OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 3 of 12 Trans ID: LCV20223716999 Law Office of Alphonso H. Ibrahim BY: Ada Gallicchio, Esq. Attorney ID#: 015692000 PO Box 6835 Scranton, PA 18505-6835 856-596-7778 Attorneys for Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street Plaintiff: SUPERIOR COURT OF NEW JERSEY LORI CARR, LAW DIVISION: OCEAN CO. DOCKET NO.: OCN-L-2045-22 vs. * CIVIL ACTION Defendants: * ALANRIC FOOD DISTRIBUTORS, INC. ANSWER, CROSSCLAIMS & DEMANDS 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 DISTRIBUTOR CORPORATIONS 1-5. Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, by way of Answer to the Complaint filed in the within matter, says: THE PARTIES AND RELEVANT FACTS 1. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 3. Answering Defendant(s) admit(s) the allegations contained in paragraph. 4. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 5. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 6. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 7. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 8. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 9. Answering Defendant(s) is/are without sufficient knowledge or information upon which to OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 4 of 12 Trans ID: LCV20223716999 form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 10. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 11. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever. FIRST COUNT 1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, hereby incorporates by reference the answers to all paragraphs contained the First Count, as though same were fully set forth herein at length. 2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 3. Denied. 4. Denied. 5. Denied. 6. Denied. 7. Denied. 8. Denied. WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever. SECOND COUNT 1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, hereby incorporates by reference the answers to all paragraphs contained the First Count, as though same were fully set forth herein at length. 2. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 3. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 4. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 5. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 6. Answering Defendant(s) is/are without sufficient knowledge or information upon which to OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 5 of 12 Trans ID: LCV20223716999 form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 7. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). 8. Answering Defendant(s) is/are without sufficient knowledge or information upon which to form a belief and neither admit(s) nor deny(ies) same but leave(s) the Plaintiff(s) to their proof(s). WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever. THIRD COUNT 1. Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, hereby incorporates by reference the answers to all paragraphs contained the First Count, as though same were fully set forth herein at length. 2. Denied as to Answering Defendant(s). 3. Denied as to Answering Defendant(s). WHEREFORE, Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, denies liability to the Plaintiff(s) in any manner or sum whatsoever. FIRST AFFIRMATIVE DEFENSE Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, was not negligent. SECOND AFFIRMATIVE DEFENSE The damages alleged were caused or contributed to by the negligence of the Plaintiff(s). THIRD AFFIRMATIVE DEFENSE Plaintiff(s) damages, if any, should be diminished by the percentage of negligence attributable to the Plaintiff in accordance with the provisions of N.J.S.A., 2A:15-5.1 et seq. FOURTH AFFIRMATIVE DEFENSE The Defendant(s) denies violating any legal duty owed to the Plaintiff(s). FIFTH AFFIRMATIVE DEFENSE The damages alleged were the proximate result of the negligence of third parties over whom this Defendant(s) had no control. SIXTH AFFIRMATIVE DEFENSE The damages alleged were the proximate result of the negligence of Co-Defendants over whom this Defendant(s) had no control. OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 6 of 12 Trans ID: LCV20223716999 SEVENTH AFFIRMATIVE DEFENSE Plaintiffs’ Complaint fails to state a cause of action against this Defendant upon which relief can be granted. EIGHTH AFFIRMATIVE DEFENSE The Plaintiff altered, modified and misused the product causing or contributing to the defect alleged. NINTH AFFIRMATIVE DEFENSE Third parties altered, modified and misused the product causing or contributing to the defect alleged. TENTH AFFIRMATIVE DEFENSE Co-Defendants altered, modified and misused the product causing or contributing to the defect alleged. ELEVENTH AFFIRMATIVE DEFENSE This cause of action is barred by N.J.S.A. 2A:14-2. TWELFTH AFFIRMATIVE DEFENSE Answering Defendant’s liability is limited to the terms of an express warranty. THIRTEENTH AFFIRMATIVE DEFENSE The Plaintiff voluntarily and unreasonably encountered a known hazard thereby barring or limiting recovery for the defect alleged. FOURTEENTH AFFIRMATIVE DEFENSE Plaintiff intentionally exposed himself to a known hazard with foreknowledge of the probable results thereby barring or limiting the recovery for the defect alleged. FIFTEENTH AFFIRMATIVE DEFENSE Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, is not liable to the Plaintiff(s) because the product in question (1) was reasonably fit, suitable and safe for its intended purpose; (2) did not deviate from the design specifications, formula, or performance standards of the manufacturer or from otherwise identical units manufactured to the same manufacturing specifications or formula; (3) contained adequate warnings and instructions; and (4) was not designed in a defective manner. N.J.S.A. 2A:58c-2. SIXTEENTH AFFIRMATIVE DEFENSE Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is not liable to the Plaintiff(s) for any alleged design defect because at the time the product left its control, there was not a practical and technically feasible design that would have prevented the harm without OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 7 of 12 Trans ID: LCV20223716999 substantially impairing the reasonably anticipated or intended function of the product. N.J.S.A. 2A:58c-3(a)(1). SEVENTEENTH AFFIRMATIVE DEFENSE The product in question has or had usefulness, is not or was not egregiously unsafe or ultra- hazardous, and the ordinary user or consumer can or could have reasonably been expected to have knowledge of the product's risk. N.J.S.A. 2A:58c-3(b). EIGHTEENTH AFFIRMATIVE DEFENSE Answering Defendant is not liable to Plaintiff(s) for any alleged design defect because 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). NINETEENTH AFFIRMATIVE DEFENSE Any danger posed by the product in question cannot or could not have been feasibly eliminated without impairing the usefulness of the product. N.J.S.A. 2A:58c-3(a)(2). TWENTIETH AFFIRMATIVE DEFENSE Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is not liable to the Plaintiff(s) for any alleged design defect because the alleged harm was caused by an unavoidably unsafe aspect of the product and the product was accompanies by an adequate warning or instruction. N.J.S.A. 2A:58c-3(a)(3). TWENTY-FIRST AFFIRMATIVE DEFENSE Answering Defendant is not liable to Plaintiff(s) for any alleged harm caused by a failure to warn because the product in question contains or contained an adequate warning or instruction. N.J.S.A. 2A:58c-4. TWENTY-SECOND AFFIRMATIVE DEFENSE Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street is not liable to the Plaintiff(s) for any alleged harm caused by a failure to warn with respect to the product because the warning or instruction provided, communicated or communicates adequate information on the dangers and safe use of the product, taking into account the characteristics of, and the ordinary knowledge common to, the persons by whom the product was intended to be used. N.J.S.A. 2A:58c-4. OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 8 of 12 Trans ID: LCV20223716999 CROSSCLAIM FOR CONTRIBUTION While denying liability for damages to the Plaintiff(s), Lori Carr, should Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street be adjudged liable to the Plaintiff(s), Answering Defendant(s) asserts that Co-Defendant(s) ALANRIC FOOD DISTRIBUTORS, INC. D/B/A FERRERA FOODS AND CENTO FINE FOODS are joint tortfeasors and therefore, Answering Defendant(s) demands contribution pursuant to the Joint Tortfeasor Act, N.J.S.A. 2A:53A-1, et seq., the Comparative Negligence Act of New Jersey, N.J.S.A., 2A:15-5.1 et seq. and Rule 4:7-5. CROSSCLAIM FOR INDEMNIFICATION Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, asserts that he/she is entitled to be indemnified and saved harmless from all loss or liability including attorneys fees and defense costs arising from the litigation by the Co-Defendant(s) pursuant to common law and/or contract. Answering Defendant(s) further asserts that his/her alleged wrongdoing, if any, was secondary, imputed and vicarious and that the alleged tortuous wrongdoing, if any, of the Co-Defendant(s) was the primary, active and direct cause of the damages alleged by the Plaintiff(s). REPLY TO ALL CROSSCLAIMS Answering Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, denies that he/she is responsible for either indemnification or contribution to the Co-Defendant(s) on any Crossclaim that is presently asserted against her or may be asserted against him/her. NOTICE PURSUANT TO RULES 1:5-1(a) AND 4:17-4(c) AND 4:17-4(f) TAKE NOTICE that the undersigned attorney, counsel for the Answering Defendant(s), does hereby demand, pursuant to Rules 1:5-1(a) and 4:17-4(c) that each party herein serving pleadings and Interrogatories and receiving answers thereto, serve copies of all such pleadings and answered Interrogatories received from any party upon the undersigned attorney and TAKE NOTICE that this is a continuing demand. Further, demand is made under Rule 4:17-4(f), whereby a plaintiff or a counterclaimant in any action in which damages are sought for personal injuries shall serve, contemporaneous with his or her answers to interrogatories, an executed form authorizing disclosure to the opposing party or parties, for purposes of the litigation, of the plaintiff's or counterclaimant's medical records pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 42 U.S.C. §§ 1301 et seq., as to each health care provider named in his or her answers to interrogatories excluding non-treating expert witnesses. OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 9 of 12 Trans ID: LCV20223716999 DEMAND FOR WRITTEN STATEMENT OF DAMAGES CLAIMED Demand is hereby made upon Plaintiff(s) to furnish within five (5) days of the receipt of this Answer, a Written Statement of the Amount of Damages Claimed pursuant to Rule 4:5-2. RESERVATION OF DEFENSES AND OBJECTIONS This Defendant hereby reserves the right to interpose such other defenses and objections as a continuing investigation may disclose. DEMAND FOR A TRIAL BY JURY Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street, hereby demands a trial by jury as to all the issues. CERTIFICATION PURSUANT TO RULE 4:5-1 The matter in controversy is not the subject of any other known action pending in any Court, or of a pending or contemplated arbitration proceeding. There are no other parties known who should be joined in this action. CERTIFICATION OF SERVICE I hereby certify that a copy of the within pleading was served within the time prescribed by Rule 4:6-1. DESIGNATION OF TRIAL COUNSEL PLEASE TAKE NOTICE that pursuant to Rule 4:25-4, Ada Gallicchio, Esq. is hereby designated trial counsel. Law Office of Alphonso H. Ibrahim Attorney for Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street BY: Ada Gallicchio, Esq. DATED: October 21, 2022 OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 10 of 12 Trans ID: LCV20223716999 DEMAND FOR ANSWERS TO INTERROGATORIES PLEASE TAKE NOTICE that the Answering Defendant(s) demands answers from the Plaintiff(s) to Uniform Interrogatories, Form A and Supplemental Interrogatories, Demand for Production of Documents as set forth in Appendix II of the New Jersey Court, and demands answers from the Co- Defendant(s) to Uniform Interrogatories C and C1, as set forth in Appendix II of the New Jersey Court and Demand for Documents. Law Office of Alphonso H. Ibrahim Attorney for Defendant(s), Mulberry Street Italian Food Center Inc T/A Mulberry Street BY: Ada Gallicchio, Esq. DATED: October 21, 2022 OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 11 of 12 Trans ID: LCV20223716999 AUTHORIZATION TO DISCLOSE INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION PHOTOCOPY WILL BE ACCEPTED AS ORIGINAL I, ___________________________________, hereby authorize the release of documents described below to: Plaintiff Name Recipient: Liberty Mutual Insurance Company Law Office of Alphonso H. Ibrahim Peerless Insurance Company 1 Executive Drive Ohio Casualty OR Marlton Executive Park, 4th Floor Safeco Insurance Company Marlton, NJ 08053 CASE NAME: CARR vs. MULBERRY STREET, et al. Provider: Patient Name: ___________________________________________________ Date of Birth: Social Security #: XXX-XX- To Whom It May Concern: This authorizes the physicians, hospital and all medical attendants to furnish full and complete medical reports and information requested. This authorization also pertains to examination of all medical records, hospital records, x-ray reports and films or copies thereof, relating to examination, consultation, confinement or treatment, inclusive of care rendered for psychiatric, drug or alcohol related disorders. This request is for the purpose of LITIGATION. I understand that the terms of this authorization are governed by the health Insurance Portability and Accountability Act of 1996 and its implementing regulations (HIPAA). I understand that I have the right to revoke this authorization, at any time prior to the compliance with the request set forth herein, provided that the revocation is in writing. I understand that my revocation must include my name, address, telephone number, date of this authorization and my signature and that I should send it to: Name and address of Provider I understand that the information used or disclosed pursuant to this authorization may be subject to re-disclosure by the Recipient and in that case, will no longer be protected by HIPAA. I understand that if my medical records contain information related to the history, diagnosis and/ or treatment of any psychiatric problems, mental illness, drug abuse, alcoholism, sexually transmitted or communicable disease, AIDS, or test for infection with human immunodeficiency virus (HIV), that my signing this document authorized the above named provider to release that information. I acknowledge and am aware that New Jersey has a statutory privilege accorded to confidential communications between a patient and a licensed physician or psychologist and that my signing this form waives this privilege. check here indicates that I believe my medical records may contain DNA test results or other genetic information. Such information is specially protected by New Jersey law, and I will be contacted for separate, specific consent prior to release of this information. This authorization is being made voluntarily and expires upon release of the information described above or upon the completion and resolution of the litigation, whichever comes first. I am willing that a photocopy of this authorization be accepted with the same authority as the original. Patient Signature: (Plaintiff) Patient Name: Date: (Please print) OCN-L-002045-22 10/21/2022 9:31:24 AM Pg 12 of 12 Trans ID: LCV20223716999 AUTHORIZATION FOR EMPLOYMENT RECORDS PHOTOCOPY WILL BE ACCEPTED AS AN ORIGINAL TO: RE: CARR vs. MULBERRY STREET, et al. To Whom It May Concern: I, ___________________________________, hereby request and authorize the release of documents described below to: Recipient: Liberty Mutual Insurance Company Law Office of Alphonso H. Ibrahim Peerless Insurance Company 1 Executive Drive Ohio Casualty OR Marlton Executive Park, 4th Floor Safeco Insurance Company Marlton, NJ 08053 Any or all records in your Personnel and/or Employment file regarding _____________________________________ DOB:___________________, including but not limited to employment application, employment physicals, worker's compensation records, salary history, personnel reports, personnel evaluations, W-4 forms, and any or all records in your file. SIGNATURE: OCN-L-002045-22 10/21/2022 OCN-L-002045-22 10/21/20229:31:24 9:31:18AM AM Pg 1 of 1 Trans TransID: ID:LCV20223716999 LCV20223716999 Civil Case Information Statement Case Details: OCEAN | Civil Part Docket# L-002045-22 Case Caption: CARR LORI VS ALANRIC FOOD DISTRIB Case Type: PERSONAL INJURY UTORS, IN Document Type: Answer W/CrossClaim W/Jury Demand Case Initiation Date: 09/15/2022 Jury Demand: YES - 6 JURORS Attorney Name: ADA SACHTER GALLICCHIO Is this a professional malpractice case? NO Firm Name: LIBERTY MUTUAL INSURANCE CO Related cases pending: NO Address: PO BOX 6835 If yes, list docket numbers: SCRANTON PA 185056835 Do you anticipate adding any parties (arising out of same Phone: 8565967778 transaction or occurrence)? NO Name of Party: DEFENDANT : MULBERRY STREET Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): LIBERTY MUTUAL INS CO Are sexual abuse claims alleged by: LORI CARR? 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) 10/21/2022 /s/ ADA SACHTER GALLICCHIO Dated Signed