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MON-L-003565-22 04/11/2023 12:56:44 PM Pg 1 of 9 Trans ID: LCV20231237615
Christopher D. Adams, Esq. (ID #012361999)
Joel Clymer, Esq. (ID #073232013)
Marjan Moussavian, Esq. (ID #304572019)
GREENBAUM, ROWE, SMITH & DAVIS LLP
River Centre Building 1
33 Newman Springs Road, Suite 122
Red Bank, New Jersey 07701
(732) 476-2682
Attorneys for Defendants, Care One Management, LLC, King James Care Center of Middletown,
LLC d/b/a Care One at King James, Jim King, and Kim Gaytan
KATHLEEN FRIEDMANN, SUPERIOR COURT OF NEW JERSEY
MONMOUTH COUNTY
Plaintiff, LAW DIVISION
DOCKET NO: MON-L-003565-22
v.
CIVIL ACTION
CARE ONE MANAGEMENT, LLC; KING
JAMES CARE CENTER OF MIDDLETOWN, ANSWERING DEFENDANTS, CARE
LLC d/b/a CARE ONE AT KING JAMES; JIM ONE MANAGEMENT, LLC, KING
KING; MELISSA HICKEY; KIM GAYTAN; JAMES CARE CENTER OF
ABC CORPORATIONS 1-5 (fictitious names MIDDLETOWN, LLC d/b/a CARE ONE
describing presently unidentified business AT KING JAMES, JIM KING, AND KIM
entities); and JOHN DOES 1-5 (fictitious GAYTAN’S ANSWER TO
names describing presently unidentified COMPLAINT, AFFIRMATIVE
individuals), DEFENSES,
AND JURY DEMAND
Defendants
Defendants, Care One Management, LLC, King James Care Center of Middletown, LLC
d/b/a Care One at King James, Jim King, and Kim Gaytan (“Answering Defendants”), by and
through their counsel Greenbaum, Rowe, Smith & Davis LLP, respectfully submit their Answer
to the Complaint filed by the Plaintiff, Kathleen Friedmann (“Plaintiff”), and state as follows:
PRELIMINARY STATEMENT
This section draws legal conclusions that do not warrant a response. To the extent that any
response is required to the preliminary statement to the Complaint, Answering Defendants deny
these allegations.
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THE PARTIES
1. Answering Defendants admit that Plaintiff is an adult individual and that she was
employed as a per diem nurse with Care One at King James Care Center of Middletown for a
period of time, however, they are without the knowledge or information sufficient to form a belief
as to the truth of the remaining allegations of Paragraph 1.
2. Answering Defendants deny the allegations of Paragraph 2 and leave Plaintiff to
her proofs.
3. Answering Defendants deny the allegations of Paragraph 3 and leave Plaintiff to
her proofs.
4. Answering Defendants deny the allegations of Paragraph 4 and leave Plaintiff to
her proofs.
5. Answering Defendants deny the allegations of Paragraph 5 and leave Plaintiff to
her proofs.
6. Answering Defendants deny the allegations of Paragraph 6 and leave Plaintiff to
her proofs.
7. The allegations of this paragraph are not directed toward the Answering Defendants
and, therefore, no response is required. To the extent a response is required, Answering Defendants
deny the allegations of Paragraph 7.
8. The allegations of this paragraph are not directed toward the Answering Defendants
and, therefore, no response is required. To the extent a response is required, Answering Defendants
deny the allegations of Paragraph 8.
9. Answering Defendants deny the allegations of Paragraph 9 as conclusions of law.
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AS TO “FACTS COMMON TO ALL CLAIMS”
10. Admitted.
11. Admitted.
12. Admitted.
13. Answering Defendants admit that they maintained policies and procedures that
prohibited retaliation against employees for reporting unethical conduct, however, the remaining
allegations of Paragraph 13 are denied.
14. Answering Defendants admit that they instituted policies and procedures that
prohibited retaliation against employees for reporting violations of the Answering Defendants’
policies, however, the remaining allegations of Paragraph 14 are denied.
15. Answering Defendants admit that Plaintiff commenced her employment in April
2019, however, they are without the knowledge or information sufficient to form a belief as to the
truth of the remaining allegations of Paragraph 15.
16. Answering Defendants lack the knowledge or information sufficient to form a
belief as to the truth of the allegations of Paragraph 16.
17. Denied.
18. Denied.
19. Denied.
To the extent any response is required to the heading placed between these
paragraphs of the Complaint, Answering Defendants deny the allegation.
20. Answering Defendants lack the knowledge or information sufficient to form a
belief as to the truth of the allegations of paragraph 20.
21. Denied.
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22. Answering Defendants admit that some of its patients required medication to be
routinely dispensed at certain times of the day and that all medication, including critical
medications, were dispensed safely and appropriately, however, they are without the knowledge
or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph
22.
23. Denied.
24. The allegations of this paragraph are denied as conclusions of law.
25. The allegations of this paragraph are denied as conclusions of law.
26. The allegations of this paragraph are denied as conclusions of law.
27. Denied.
28. Denied.
29. Denied.
To the extent any response is required to the heading placed between these
paragraphs of the Complaint, Answering Defendants deny the allegation.
30. Answering Defendants lack the knowledge or information sufficient to form a
belief as to the truth of the allegations of Paragraph 30.
31. Answering Defendants lack the knowledge or information sufficient to form a
belief as to the truth of the allegations of Paragraph 31.
32. Answering Defendants lack the knowledge or information sufficient to form the
belief as to the truth of the allegations of Paragraph 32.
33. Answering Defendants lack the knowledge or information sufficient to form the
belief as to whether the email was drafted and sent by the Plaintiff, which email is a document that
speaks for itself.
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34. Answering Defendants lack the knowledge or information sufficient to form the
belief as to whether the email was drafted and sent by the Plaintiff, which email is a document that
speaks for itself.
35. Denied.
36. Denied.
37. Denied.
38. Denied.
AS TO “COUNT ONE – RETALIATION IN VIOLATION OF NEW JERSEY
CONSCIENTIOUS EMPLOYEE PROTECTION ACT (“CEPA”)”
39. Answering Defendants repeat and reassert their answers to each and every
allegation contained in the Complaint as if set forth herein at length.
40. Denied.
41. Denied.
42. Denied.
43. The allegations of this paragraph are denied as conclusions of law.
44. Denied.
AS TO “COUNT TWO – WRONGFUL DISCHARGE IN VIOLATION
OF PUBLIC POLICY”
1. Answering Defendants repeat and reassert their answers to each and every
allegation contained in the Complaint as if set forth herein at length.
2. Denied.
3. Denied.
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AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
The Complaint, in whole or in part, fails to state a claim upon which relief may be granted.
SECOND AFFIRMATIVE DEFENSE
Recovery is barred in this action by reason of any applicable statute of limitations.
THIRD AFFIRMATIVE DEFENSE
Plaintiff’s claims are barred by the doctrines of collateral estoppel and/or res judicata
and/or entire controversy and/or issue preclusion.
FOURTH AFFIRMATIVE DEFENSE
Plaintiff has not been deprived of any right, privilege, or immunity secured to him by the
Constitution and laws of the State of New Jersey.
FIFTH AFFIRMATIVE DEFENSE
Answering Defendants herein acted at all times relevant hereto in good faith and without
any fraud or malice.
SIXTH AFFIRMATIVE DEFENSE
Plaintiff’s claims are barred by virtue of the doctrine of unclean hands, waiver, and/or
laches.
SEVENTH AFFIRMATIVE DEFENSE
Plaintiff suffered no harassment, discriminatory or retaliatory treatment.
EIGHTH AFFIRMATIVE DEFENSE
Answering Defendants did not violate any provisions of CEPA, N.J.S.A. 34:19-1 et seq.
NINTH AFFIRMATIVE DEFENSE
All personnel actions taken with regard to Plaintiff were done for non-
discriminatory/retaliatory and legitimate business reasons.
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TENTH AFFIRMATIVE DEFENSE
Answering Defendants have an effective policy against discrimination, harassment, and
retaliation, with remedial measures.
ELEVENTH AFFIRMATIVE DEFENSE
Plaintiff’s damages, if any, are barred because Plaintiff failed to mitigate her damages.
TWELFTH AFFIRMATIVE DEFENSE
Plaintiff’s claims have been instituted and maintained in bad faith and, therefore,
Answering Defendants are entitled to their attorney’s fees, costs of suit, and such other relief as
the Court deems proper and just.
THIRTEENTH AFFIRMATIVE DEFENSE
Plaintiff is not entitled to punitive damages.
FOURTEENTH AFFIRMATIVE DEFENSE
Plaintiff unreasonably failed to take advantage of available preventative or corrective
opportunities provided by the Answering Defendants or to otherwise avoid harm.
FIFTEENTH AFFIRMATIVE DEFENSE
Answering Defendants did not retaliate against Plaintiff based on any reports, complaints,
or for any other reason.
SIXTEENTH AFFIRMATIVE DEFENSE
Answering Defendants did not wrongfully discharge Plaintiff in violation of public policy.
JURY DEMAND
Answering Defendants demand a trial by jury on all issues.
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DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4:25, Christopher D. Adams, Esq. is designated as trial counsel for the
Answering Defendants.
REQUEST FOR STATEMENT OF DAMAGES
Pursuant to R. 4:5-2 please provide a statement of the amount of damages claimed in this
action.
GREENBAUM, ROWE, SMITH & DAVIS, LLP
Attorneys for Defendants, Care One Management,
LLC, King James Care Center of Middletown, LLC
d/b/a Care One at King James, Jim King, and Kim
Gaytan
By:___/s/ Christopher D. Adams
CHRISTOPHER D. ADAMS, ESQ.
Dated: April 11, 2023
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CERTIFICATION PURSUANT TO R. 4:5-1
To the best of my knowledge, information and belief, the matter in controversy is not the
subject of any other action pending in any other court or of a pending arbitration proceeding, nor
is any action or arbitration proceeding contemplated. At the present time, and prior to discovery,
I know of no other parties who should be joined in the within action.
CERTIFICATION PURSUANT TO R. 1:38-7
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).
CERTIFICATION OF TIMELY SERVICE
I certify that the foregoing Answer, Affirmative Defenses, and Designation of Trial
Counsel is being filed and served within the time permitted by the Rules of Court, as modified by
the stipulation of the parties.
/s/ Christopher D. Adams
CHRISTOPHER D. ADAMS, ESQ.
Dated: April 11, 2023
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Civil Case Information Statement
Case Details: MONMOUTH | Civil Part Docket# L-003565-22
Case Caption: FRIEDMANN KATHLEEN VS CARE ONE Case Type: WHISTLEBLOWER / CONSCIENTIOUS EMPLOYEE
MANAGEMENT, LLC. PROTECTION ACT (CEPA)
Case Initiation Date: 12/30/2022 Document Type: Answer W/Jury Demand
Attorney Name: JOEL CLYMER Jury Demand: YES - 6 JURORS
Firm Name: GREENBAUM ROWE SMITH & DAVIS, LLP Is this a professional malpractice case? NO
Address: METRO CORPORATE CAMPUS ONE PO BOX Related cases pending: NO
5600 If yes, list docket numbers:
WOODBRIDGE NJ 070950988 Do you anticipate adding any parties (arising out of same
Phone: 7325495600 transaction or occurrence)? NO
Name of Party: DEFENDANT : CARE ONE Does this case involve claims related to COVID-19? NO
MANAGEMENT,LLC.
Name of Defendant’s Primary Insurance Company Are sexual abuse claims alleged by: KATHLEEN FRIEDMANN? NO
(if known): None
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? YES
If yes, is that relationship: Employer/Employee
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)
04/11/2023 /s/ JOEL CLYMER
Dated Signed
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Preview
MON-L-003565-22 04/11/2023 12:56:44 PM Pg 1 of 9 Trans ID: LCV20231237615 Christopher D. Adams, Esq. (ID #012361999) Joel Clymer, Esq. (ID #073232013) Marjan Moussavian, Esq. (ID #304572019) GREENBAUM, ROWE, SMITH & DAVIS LLP River Centre Building 1 33 Newman Springs Road, Suite 122 Red Bank, New Jersey 07701 (732) 476-2682 Attorneys for Defendants, Care One Management, LLC, King James Care Center of Middletown, LLC d/b/a Care One at King James, Jim King, and Kim Gaytan KATHLEEN FRIEDMANN, SUPERIOR COURT OF NEW JERSEY MONMOUTH COUNTY Plaintiff, LAW DIVISION DOCKET NO: MON-L-003565-22 v. CIVIL ACTION CARE ONE MANAGEMENT, LLC; KING JAMES CARE CENTER OF MIDDLETOWN, ANSWERING DEFENDANTS, CARE LLC d/b/a CARE ONE AT KING JAMES; JIM ONE MANAGEMENT, LLC, KING KING; MELISSA HICKEY; KIM GAYTAN; JAMES CARE CENTER OF ABC CORPORATIONS 1-5 (fictitious names MIDDLETOWN, LLC d/b/a CARE ONE describing presently unidentified business AT KING JAMES, JIM KING, AND KIM entities); and JOHN DOES 1-5 (fictitious GAYTAN’S ANSWER TO names describing presently unidentified COMPLAINT, AFFIRMATIVE individuals), DEFENSES, AND JURY DEMAND Defendants Defendants, Care One Management, LLC, King James Care Center of Middletown, LLC d/b/a Care One at King James, Jim King, and Kim Gaytan (“Answering Defendants”), by and through their counsel Greenbaum, Rowe, Smith & Davis LLP, respectfully submit their Answer to the Complaint filed by the Plaintiff, Kathleen Friedmann (“Plaintiff”), and state as follows: PRELIMINARY STATEMENT This section draws legal conclusions that do not warrant a response. To the extent that any response is required to the preliminary statement to the Complaint, Answering Defendants deny these allegations. 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 2 of 9 Trans ID: LCV20231237615 THE PARTIES 1. Answering Defendants admit that Plaintiff is an adult individual and that she was employed as a per diem nurse with Care One at King James Care Center of Middletown for a period of time, however, they are without the knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 1. 2. Answering Defendants deny the allegations of Paragraph 2 and leave Plaintiff to her proofs. 3. Answering Defendants deny the allegations of Paragraph 3 and leave Plaintiff to her proofs. 4. Answering Defendants deny the allegations of Paragraph 4 and leave Plaintiff to her proofs. 5. Answering Defendants deny the allegations of Paragraph 5 and leave Plaintiff to her proofs. 6. Answering Defendants deny the allegations of Paragraph 6 and leave Plaintiff to her proofs. 7. The allegations of this paragraph are not directed toward the Answering Defendants and, therefore, no response is required. To the extent a response is required, Answering Defendants deny the allegations of Paragraph 7. 8. The allegations of this paragraph are not directed toward the Answering Defendants and, therefore, no response is required. To the extent a response is required, Answering Defendants deny the allegations of Paragraph 8. 9. Answering Defendants deny the allegations of Paragraph 9 as conclusions of law. -2- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 3 of 9 Trans ID: LCV20231237615 AS TO “FACTS COMMON TO ALL CLAIMS” 10. Admitted. 11. Admitted. 12. Admitted. 13. Answering Defendants admit that they maintained policies and procedures that prohibited retaliation against employees for reporting unethical conduct, however, the remaining allegations of Paragraph 13 are denied. 14. Answering Defendants admit that they instituted policies and procedures that prohibited retaliation against employees for reporting violations of the Answering Defendants’ policies, however, the remaining allegations of Paragraph 14 are denied. 15. Answering Defendants admit that Plaintiff commenced her employment in April 2019, however, they are without the knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 15. 16. Answering Defendants lack the knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 16. 17. Denied. 18. Denied. 19. Denied. To the extent any response is required to the heading placed between these paragraphs of the Complaint, Answering Defendants deny the allegation. 20. Answering Defendants lack the knowledge or information sufficient to form a belief as to the truth of the allegations of paragraph 20. 21. Denied. -3- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 4 of 9 Trans ID: LCV20231237615 22. Answering Defendants admit that some of its patients required medication to be routinely dispensed at certain times of the day and that all medication, including critical medications, were dispensed safely and appropriately, however, they are without the knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 22. 23. Denied. 24. The allegations of this paragraph are denied as conclusions of law. 25. The allegations of this paragraph are denied as conclusions of law. 26. The allegations of this paragraph are denied as conclusions of law. 27. Denied. 28. Denied. 29. Denied. To the extent any response is required to the heading placed between these paragraphs of the Complaint, Answering Defendants deny the allegation. 30. Answering Defendants lack the knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 30. 31. Answering Defendants lack the knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 31. 32. Answering Defendants lack the knowledge or information sufficient to form the belief as to the truth of the allegations of Paragraph 32. 33. Answering Defendants lack the knowledge or information sufficient to form the belief as to whether the email was drafted and sent by the Plaintiff, which email is a document that speaks for itself. -4- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 5 of 9 Trans ID: LCV20231237615 34. Answering Defendants lack the knowledge or information sufficient to form the belief as to whether the email was drafted and sent by the Plaintiff, which email is a document that speaks for itself. 35. Denied. 36. Denied. 37. Denied. 38. Denied. AS TO “COUNT ONE – RETALIATION IN VIOLATION OF NEW JERSEY CONSCIENTIOUS EMPLOYEE PROTECTION ACT (“CEPA”)” 39. Answering Defendants repeat and reassert their answers to each and every allegation contained in the Complaint as if set forth herein at length. 40. Denied. 41. Denied. 42. Denied. 43. The allegations of this paragraph are denied as conclusions of law. 44. Denied. AS TO “COUNT TWO – WRONGFUL DISCHARGE IN VIOLATION OF PUBLIC POLICY” 1. Answering Defendants repeat and reassert their answers to each and every allegation contained in the Complaint as if set forth herein at length. 2. Denied. 3. Denied. -5- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 6 of 9 Trans ID: LCV20231237615 AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE The Complaint, in whole or in part, fails to state a claim upon which relief may be granted. SECOND AFFIRMATIVE DEFENSE Recovery is barred in this action by reason of any applicable statute of limitations. THIRD AFFIRMATIVE DEFENSE Plaintiff’s claims are barred by the doctrines of collateral estoppel and/or res judicata and/or entire controversy and/or issue preclusion. FOURTH AFFIRMATIVE DEFENSE Plaintiff has not been deprived of any right, privilege, or immunity secured to him by the Constitution and laws of the State of New Jersey. FIFTH AFFIRMATIVE DEFENSE Answering Defendants herein acted at all times relevant hereto in good faith and without any fraud or malice. SIXTH AFFIRMATIVE DEFENSE Plaintiff’s claims are barred by virtue of the doctrine of unclean hands, waiver, and/or laches. SEVENTH AFFIRMATIVE DEFENSE Plaintiff suffered no harassment, discriminatory or retaliatory treatment. EIGHTH AFFIRMATIVE DEFENSE Answering Defendants did not violate any provisions of CEPA, N.J.S.A. 34:19-1 et seq. NINTH AFFIRMATIVE DEFENSE All personnel actions taken with regard to Plaintiff were done for non- discriminatory/retaliatory and legitimate business reasons. -6- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 7 of 9 Trans ID: LCV20231237615 TENTH AFFIRMATIVE DEFENSE Answering Defendants have an effective policy against discrimination, harassment, and retaliation, with remedial measures. ELEVENTH AFFIRMATIVE DEFENSE Plaintiff’s damages, if any, are barred because Plaintiff failed to mitigate her damages. TWELFTH AFFIRMATIVE DEFENSE Plaintiff’s claims have been instituted and maintained in bad faith and, therefore, Answering Defendants are entitled to their attorney’s fees, costs of suit, and such other relief as the Court deems proper and just. THIRTEENTH AFFIRMATIVE DEFENSE Plaintiff is not entitled to punitive damages. FOURTEENTH AFFIRMATIVE DEFENSE Plaintiff unreasonably failed to take advantage of available preventative or corrective opportunities provided by the Answering Defendants or to otherwise avoid harm. FIFTEENTH AFFIRMATIVE DEFENSE Answering Defendants did not retaliate against Plaintiff based on any reports, complaints, or for any other reason. SIXTEENTH AFFIRMATIVE DEFENSE Answering Defendants did not wrongfully discharge Plaintiff in violation of public policy. JURY DEMAND Answering Defendants demand a trial by jury on all issues. -7- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 8 of 9 Trans ID: LCV20231237615 DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4:25, Christopher D. Adams, Esq. is designated as trial counsel for the Answering Defendants. REQUEST FOR STATEMENT OF DAMAGES Pursuant to R. 4:5-2 please provide a statement of the amount of damages claimed in this action. GREENBAUM, ROWE, SMITH & DAVIS, LLP Attorneys for Defendants, Care One Management, LLC, King James Care Center of Middletown, LLC d/b/a Care One at King James, Jim King, and Kim Gaytan By:___/s/ Christopher D. Adams CHRISTOPHER D. ADAMS, ESQ. Dated: April 11, 2023 -8- 8396959.2 MON-L-003565-22 04/11/2023 12:56:44 PM Pg 9 of 9 Trans ID: LCV20231237615 CERTIFICATION PURSUANT TO R. 4:5-1 To the best of my knowledge, information and belief, the matter in controversy is not the subject of any other action pending in any other court or of a pending arbitration proceeding, nor is any action or arbitration proceeding contemplated. At the present time, and prior to discovery, I know of no other parties who should be joined in the within action. CERTIFICATION PURSUANT TO R. 1:38-7 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). CERTIFICATION OF TIMELY SERVICE I certify that the foregoing Answer, Affirmative Defenses, and Designation of Trial Counsel is being filed and served within the time permitted by the Rules of Court, as modified by the stipulation of the parties. /s/ Christopher D. Adams CHRISTOPHER D. ADAMS, ESQ. Dated: April 11, 2023 -9- 8396959.2 MON-L-003565-22 04/11/2023 MON-L-003565-22 04/11/202312:56:44 12:55:02PM PM Pg 1 of 2 Trans TransID: ID:LCV20231237615 LCV20231237615 Civil Case Information Statement Case Details: MONMOUTH | Civil Part Docket# L-003565-22 Case Caption: FRIEDMANN KATHLEEN VS CARE ONE Case Type: WHISTLEBLOWER / CONSCIENTIOUS EMPLOYEE MANAGEMENT, LLC. PROTECTION ACT (CEPA) Case Initiation Date: 12/30/2022 Document Type: Answer W/Jury Demand Attorney Name: JOEL CLYMER Jury Demand: YES - 6 JURORS Firm Name: GREENBAUM ROWE SMITH & DAVIS, LLP Is this a professional malpractice case? NO Address: METRO CORPORATE CAMPUS ONE PO BOX Related cases pending: NO 5600 If yes, list docket numbers: WOODBRIDGE NJ 070950988 Do you anticipate adding any parties (arising out of same Phone: 7325495600 transaction or occurrence)? NO Name of Party: DEFENDANT : CARE ONE Does this case involve claims related to COVID-19? NO MANAGEMENT,LLC. Name of Defendant’s Primary Insurance Company Are sexual abuse claims alleged by: KATHLEEN FRIEDMANN? NO (if known): None 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? YES If yes, is that relationship: Employer/Employee 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) 04/11/2023 /s/ JOEL CLYMER Dated Signed MON-L-003565-22 04/11/2023 MON-L-003565-22 04/11/202312:56:44 12:55:02PM PM Pg 2 of 2 Trans TransID: ID:LCV20231237615 LCV20231237615