Preview
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 1 of 10 Trans ID: LCV20223698120
LAW OFFICES
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
STEPHEN J. FOLEY, JR. ——— RALPH W. CAMPBELL
MARIO J. DELANO § 1599 HIGHWAY 34, BLDG. E (1952-1993)
PATRICIA B. ADAMS P.O. BOX 1570 JOHN J. LEE
WALL, N.J. 07719-1570 (1950-2001)
LEWIS M. MARKOWITZ
MICHAEL J. CERNIGLIARO
SUSAN FOX BRENNAN (1963-2011)
STEPHEN CZESLOWSKI □ TELE 732-775-6520
——— FRANCIS J. MURPHY
HELEN A. CUMMINGS (1953-2012)
GENERAL/CALENDAR FAX 732-869-2893
CHRISTIAN E. SCHLEGEL▲ STEPHEN J. FOLEY
——— (1954-2015)
Certified by the Supreme Court
of New Jersey as a Civil Trial Attorney
Admitted to the U.S.Supreme Court
§ NJ & PA BAR
□ NJ & NY BAR
▲ NJ, DC & VA BAR
October 19, 2022
Deputy Clerk
Superior Court of Monmouth County
Motions Division
71 Monument Park,
Freehold, NJ 07728-1266
Re: Case v. NJM
Docket No. MON-L-1518-22
File No. 41-40,455-PBA
Dear Sir/Madam:
Enclosed please find the following with reference to the above captioned matter:
(xx)Order
(xx)Notice of Motion to Dismiss Plaintiff Complaint for Failure to Provide Discovery
With respect to the above, kindly
(xx)File/Record
(xx)Charge to Account #11900
Very truly yours,
PATRICIA B. ADAMS, ESQ.
PBA/cl
cc: Evan D. Baker, Esq.
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 2 of 10 Trans ID: LCV20223698120
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
P. O. Box 1570, 1599 HWY 34, BLDG. E.
WALL, NJ 07719-1570
(732) 775-6520
Attorneys for Defendant, NJM
File No. 41-40,455-PBA
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
MONMOUTH COUNTY
DOCKET NO: MON-L-1518-22
MOTIONS:
The original of the within Notice of Motion has been filed with the Clerk of the County of Monmouth at
Freehold, New Jersey.
A copy of the within Notice of Motion has been filed with all counsel.
Dated: 10/19/2022
__________________________
PATRICIA B. ADAMS, ESQ.
Attorney for Defendant, NJM
PROOF OF MAILING: I, the undersigned, mailed the following: NOTICE OF MOTION TO DISMISS
PLAINTIFF COMPLAINT FOR FAILURE TO PROVIDE DISCOVERY by email transmission through eCourts,
or if the party or its firm was not a registered user, by Regular mail, to:
Evan D. Baker, Esq.
I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing
statements made by me are willfully false, I am subject to punishment.
__________________________
PATRICIA B. ADAMS, ESQ.
Dated: 10/19/2022
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 3 of 10 Trans ID: LCV20223698120
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
PATRICIA B. ADAMS, ESQ. 014321995
1599 HWY 34, BLDG. E.
P. O. Box 1570
WALL, NEW JERSEY 07719-1570
Telephone: (732) 775-6520
Attorneys for Defendant, NJM
Our File No. 41-40,455-PBA
__________________________________________
Plaintiff, SUPERIOR COURT OF NEW JERSEY
MARC CASE LAW DIVISION: MONMOUTH COUNTY
DOCKET NO: MON-L-1518-22
vs.
CIVIL ACTION
Defendants,
NEW JERSEY MANUFACTURERS INSURANCE NOTICE OF MOTION TO DISMISS PLAINTIFF
COMPANY, JOHN DOES 1-10 (FICTITIOUS COMPLAINT FOR FAILURE TO PROVIDE DISCOVERY
NAMES REPRESENTING UNKNOWN
INDIVIDUALS) AND/OR XYZ CORPS. 1-10
(FICTITIOUS NAMES REPRESENTING
UNKNOWN CORPORATIONS, PARTNERSHIPS
AND/OR LIMITED LIABILITY COMPANIES OR
OTHER TYPES OF LEGAL ENTITIES)
__________________________________________
TO: Evan D. Baker, Esq.
Davis, Saperstein & Salomon, P.C.
375 Cedar Lane,
Teaneck, NJ 07666-3433
SIR/MADAM:
PLEASE TAKE NOTICE, that on Friday the 4th day of November, 2022, at 9:00 A.M. in the forenoon,
or as soon thereafter as counsel may be heard at the Court House, Freehold New Jersey, the undersigned will
apply to the Assignment Judge of Monmouth County or such judge as may be sitting in his/her place, for an
ORDER to dismiss plaintiff complaint for failure to provide discovery.
IN SUPPORT OF THIS MOTION, the undersigned will rely upon the Certification annexed hereto.
It is respectfully requested that the Court rule on the motion based upon the attached documents
pursuant to R.1:6 2. An Order granting the relief requested is submitted herewith.
CAMPBELL, FOLEY, DELANO & ADAMS, LLC
Attorneys for Defendant, NJM
_____________________________
PATRICIA B. ADAMS, ESQ.
Dated: 10/19/2022
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 4 of 10 Trans ID: LCV20223698120
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
PATRICIA B. ADAMS, ESQ. 014321995
1599 HWY 34, BLDG. E.
P. O. Box 1570
WALL, NEW JERSEY 07719-1570
Telephone: (732) 775-6520
Attorneys for Defendant, NJM
Our File No. 41-40,455-PBA
__________________________________________
Plaintiff, SUPERIOR COURT OF NEW JERSEY
MARC CASE LAW DIVISION: MONMOUTH COUNTY
DOCKET NO: MON-L-1518-22
vs.
CIVIL ACTION
Defendants,
NEW JERSEY MANUFACTURERS INSURANCE CERTIFICATION IN SUPPORT OF
COMPANY, JOHN DOES 1-10 (FICTITIOUS NOTICE OF MOTION TO DISMISS PLAINTIFF
NAMES REPRESENTING UNKNOWN COMPLAINT FOR FAILURE TO PROVIDE
INDIVIDUALS) AND/OR XYZ CORPS. 1-10 DISCOVERY
(FICTITIOUS NAMES REPRESENTING
UNKNOWN CORPORATIONS, PARTNERSHIPS
AND/OR LIMITED LIABILITY COMPANIES OR
OTHER TYPES OF LEGAL ENTITIES)
__________________________________________
PATRICIA B. ADAMS, ESQ., of full age, being duly sworn according to law and upon her oath deposes
and says:
1. I am an attorney at law in New Jersey and a member of the firm of Campbell, Foley, Delano & Adams,
LLC. As such, I am the one entrusted with the defense of defendant, New Jersey Manufacturers Ins.
Co., in this matter. I make this Certification in support of this defendant’s motion to dismiss plaintiff
complaint for failure to provide discovery. I make this Certification based upon personal knowledge and
my review of the file materials herein.
2. The defendant filed an Answer to the Complaint on or about September 12, 2022 and pursuant to R.
4:17-1(b)(2), the plaintiff was deemed to have been served with interrogatories. In addition, we served
the plaintiff with supplemental interrogatories by letter dated September 12, 2022 attached hereto as
Exhibit A. The Rule requires that the plaintiff provide answers to those interrogatories within 30 days of
the service of the defendant’s Answer.
3. More than thirty days has passed and, to date, we have not received answers to interrogatories from the
plaintiff and they are now overdue.
4. By letter of October 10, 2022 attached hereto as Exhibit B, we have provided the plaintiff with notice that
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 5 of 10 Trans ID: LCV20223698120
they are in default in providing answers to Form A interrogatories and Supplemental Interrogatories and
that the Complaint is subject to dismissal for this continuing non-compliance.
5. We now request that the plaintiff's Complaint be dismissed pursuant to R. 4:23-5(a)(1).
6. We are not in default in providing discovery.
7. There is a case management conference scheduled for October 27, 2022.
I certify that the foregoing statements made by
me are true. I am aware that if any of the
foregoing statements made by me are willfully false,
I am subject to punishment.
_________________________________________
PATRICIA B. ADAMS, ESQ.
Dated: 10/19 /2022
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 6 of 10 Trans ID: LCV20223698120
EXHIBIT A
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 7 of 10 Trans ID: LCV20223698120
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 8 of 10 Trans ID: LCV20223698120
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 9 of 10 Trans ID: LCV20223698120
EXHIBIT B
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LAW OFFICES
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
STEPHEN J. FOLEY, JR. ——— RALPH W. CAMPBELL
MARIO J. DELANO § 1599 HIGHWAY 34, BLDG. E (1952-1993)
PATRICIA B. ADAMS P.O. BOX 1570 JOHN J. LEE
LEWIS M. MARKOWITZ WALL, N.J. 07719-1570 (1950-2001)
SUSAN FOX BRENNAN MICHAEL J. CERNIGLIARO
STEPHEN CZESLOWSKI □ TELE 732-775-6520 (1963-2011)
HELEN A. CUMMINGS ——— FRANCIS J. MURPHY
CHRISTIAN E. SCHLEGEL▲ GENERAL/CALENDAR FAX 732-869-2893 (1953-2012)
STEPHEN J. FOLEY
Certified by the Supreme Court ———
of New Jersey as a Civil Trial Attorney
(1954-2015)
E-MAIL:
Admitted to the U.S.Supreme Court
PADAMS@CAMPBELLFOLEY.COM
§ NJ & PA BAR
□ NJ & NY BAR
▲ NJ, DC & VA BAR
October 10, 2022
Evan D. Baker, Esq.
Davis, Saperstein & Salomon, P.C.
375 Cedar Lane
Teaneck, NJ 07666-3433
Re: Case v. NJM
Docket No. MON-L-1518-19
File No. 41-40,455-PBA
Dear Mr. Baker:
By letter dated September 12, 2022, we requested certain discovery from your client, namely, answers to
interrogatories and supplemental answers to interrogatories.
You have failed to comply with our request.
Please consider this letter your notice under R. 1:6-2(c). Your continuing non-compliance with our
discovery request will result in our filing a motion to dismiss the plaintiff's Complaint under R. 4:23-5
WITHOUT FURTHER NOTICE TO YOUR OFFICE.
Very truly yours,
PATRICIA B. ADAMS, ESQ.
PBA/cl
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 1 of 1 Trans ID: LCV20223698120
CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C.
PATRICIA B. ADAMS, ESQ. 014321995
1599 HWY 34, BLDG. E.
P. O. Box 1570
WALL, NEW JERSEY 07719-1570
Telephone: (732) 775-6520
Attorneys for Defendant, NJM
Our File No. 41-40,455-PBA
___________________________________________
Plaintiff, SUPERIOR COURT OF NEW JERSEY
MARC CASE LAW DIVISION: MONMOUTH COUNTY
DOCKET NO: MON-L-1518-22
vs.
CIVIL ACTION
Defendants,
NEW JERSEY MANUFACTURERS INSURANCE ORDER TO DISMISS PLAINTIFF COMPLAINT FOR
COMPANY, JOHN DOES 1-10 (FICTITIOUS NAMES FAILURE TO PROVIDE DISCOVERY
REPRESENTING UNKNOWN INDIVIDUALS)
AND/OR XYZ CORPS. 1-10 (FICTITIOUS NAMES
REPRESENTING UNKNOWN CORPORATIONS,
PARTNERSHIPS AND/OR LIMITED LIABILITY
COMPANIES OR OTHER TYPES OF LEGAL
ENTITIES)
The above entitled matter having been opened to the Court on November 4, 2022, by Campbell, Foley,
Delano & Adams, L.L.C., attorneys for the defendant, New Jersey Manufacturers Ins. Co., on motion to dismiss
plaintiff complaint for failure to provide discovery, and it appearing to the satisfaction of the Court that the
motion may be granted, it is hereby
ORDERED on this day of , 2022, that the Complaint be and is hereby dismissed
for failure of the plaintiff, Marc Case, to provide answers to Form A interrogatories and Supplemental
Interrogatories, and it is further
ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to
eCourts. Pursuant to Rule 1:5-1(a), movant shall serve a copy of this Order on all parties not served
electronically within seven days of the date of this Order.
_____________________________________
J.S.C.
( )Opposed
( )Unopposed
Preview
MON-L-001518-22 10/19/2022 2:21:40 PM Pg 1 of 10 Trans ID: LCV20223698120 LAW OFFICES CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. STEPHEN J. FOLEY, JR. ——— RALPH W. CAMPBELL MARIO J. DELANO § 1599 HIGHWAY 34, BLDG. E (1952-1993) PATRICIA B. ADAMS P.O. BOX 1570 JOHN J. LEE WALL, N.J. 07719-1570 (1950-2001) LEWIS M. MARKOWITZ MICHAEL J. CERNIGLIARO SUSAN FOX BRENNAN (1963-2011) STEPHEN CZESLOWSKI □ TELE 732-775-6520 ——— FRANCIS J. MURPHY HELEN A. CUMMINGS (1953-2012) GENERAL/CALENDAR FAX 732-869-2893 CHRISTIAN E. SCHLEGEL▲ STEPHEN J. FOLEY ——— (1954-2015) Certified by the Supreme Court of New Jersey as a Civil Trial Attorney Admitted to the U.S.Supreme Court § NJ & PA BAR □ NJ & NY BAR ▲ NJ, DC & VA BAR October 19, 2022 Deputy Clerk Superior Court of Monmouth County Motions Division 71 Monument Park, Freehold, NJ 07728-1266 Re: Case v. NJM Docket No. MON-L-1518-22 File No. 41-40,455-PBA Dear Sir/Madam: Enclosed please find the following with reference to the above captioned matter: (xx)Order (xx)Notice of Motion to Dismiss Plaintiff Complaint for Failure to Provide Discovery With respect to the above, kindly (xx)File/Record (xx)Charge to Account #11900 Very truly yours, PATRICIA B. ADAMS, ESQ. PBA/cl cc: Evan D. Baker, Esq. MON-L-001518-22 10/19/2022 2:21:40 PM Pg 2 of 10 Trans ID: LCV20223698120 CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. P. O. Box 1570, 1599 HWY 34, BLDG. E. WALL, NJ 07719-1570 (732) 775-6520 Attorneys for Defendant, NJM File No. 41-40,455-PBA SUPERIOR COURT OF NEW JERSEY LAW DIVISION MONMOUTH COUNTY DOCKET NO: MON-L-1518-22 MOTIONS: The original of the within Notice of Motion has been filed with the Clerk of the County of Monmouth at Freehold, New Jersey. A copy of the within Notice of Motion has been filed with all counsel. Dated: 10/19/2022 __________________________ PATRICIA B. ADAMS, ESQ. Attorney for Defendant, NJM PROOF OF MAILING: I, the undersigned, mailed the following: NOTICE OF MOTION TO DISMISS PLAINTIFF COMPLAINT FOR FAILURE TO PROVIDE DISCOVERY by email transmission through eCourts, or if the party or its firm was not a registered user, by Regular mail, to: Evan D. Baker, Esq. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. __________________________ PATRICIA B. ADAMS, ESQ. Dated: 10/19/2022 MON-L-001518-22 10/19/2022 2:21:40 PM Pg 3 of 10 Trans ID: LCV20223698120 CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. PATRICIA B. ADAMS, ESQ. 014321995 1599 HWY 34, BLDG. E. P. O. Box 1570 WALL, NEW JERSEY 07719-1570 Telephone: (732) 775-6520 Attorneys for Defendant, NJM Our File No. 41-40,455-PBA __________________________________________ Plaintiff, SUPERIOR COURT OF NEW JERSEY MARC CASE LAW DIVISION: MONMOUTH COUNTY DOCKET NO: MON-L-1518-22 vs. CIVIL ACTION Defendants, NEW JERSEY MANUFACTURERS INSURANCE NOTICE OF MOTION TO DISMISS PLAINTIFF COMPANY, JOHN DOES 1-10 (FICTITIOUS COMPLAINT FOR FAILURE TO PROVIDE DISCOVERY NAMES REPRESENTING UNKNOWN INDIVIDUALS) AND/OR XYZ CORPS. 1-10 (FICTITIOUS NAMES REPRESENTING UNKNOWN CORPORATIONS, PARTNERSHIPS AND/OR LIMITED LIABILITY COMPANIES OR OTHER TYPES OF LEGAL ENTITIES) __________________________________________ TO: Evan D. Baker, Esq. Davis, Saperstein & Salomon, P.C. 375 Cedar Lane, Teaneck, NJ 07666-3433 SIR/MADAM: PLEASE TAKE NOTICE, that on Friday the 4th day of November, 2022, at 9:00 A.M. in the forenoon, or as soon thereafter as counsel may be heard at the Court House, Freehold New Jersey, the undersigned will apply to the Assignment Judge of Monmouth County or such judge as may be sitting in his/her place, for an ORDER to dismiss plaintiff complaint for failure to provide discovery. IN SUPPORT OF THIS MOTION, the undersigned will rely upon the Certification annexed hereto. It is respectfully requested that the Court rule on the motion based upon the attached documents pursuant to R.1:6 2. An Order granting the relief requested is submitted herewith. CAMPBELL, FOLEY, DELANO & ADAMS, LLC Attorneys for Defendant, NJM _____________________________ PATRICIA B. ADAMS, ESQ. Dated: 10/19/2022 MON-L-001518-22 10/19/2022 2:21:40 PM Pg 4 of 10 Trans ID: LCV20223698120 CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. PATRICIA B. ADAMS, ESQ. 014321995 1599 HWY 34, BLDG. E. P. O. Box 1570 WALL, NEW JERSEY 07719-1570 Telephone: (732) 775-6520 Attorneys for Defendant, NJM Our File No. 41-40,455-PBA __________________________________________ Plaintiff, SUPERIOR COURT OF NEW JERSEY MARC CASE LAW DIVISION: MONMOUTH COUNTY DOCKET NO: MON-L-1518-22 vs. CIVIL ACTION Defendants, NEW JERSEY MANUFACTURERS INSURANCE CERTIFICATION IN SUPPORT OF COMPANY, JOHN DOES 1-10 (FICTITIOUS NOTICE OF MOTION TO DISMISS PLAINTIFF NAMES REPRESENTING UNKNOWN COMPLAINT FOR FAILURE TO PROVIDE INDIVIDUALS) AND/OR XYZ CORPS. 1-10 DISCOVERY (FICTITIOUS NAMES REPRESENTING UNKNOWN CORPORATIONS, PARTNERSHIPS AND/OR LIMITED LIABILITY COMPANIES OR OTHER TYPES OF LEGAL ENTITIES) __________________________________________ PATRICIA B. ADAMS, ESQ., of full age, being duly sworn according to law and upon her oath deposes and says: 1. I am an attorney at law in New Jersey and a member of the firm of Campbell, Foley, Delano & Adams, LLC. As such, I am the one entrusted with the defense of defendant, New Jersey Manufacturers Ins. Co., in this matter. I make this Certification in support of this defendant’s motion to dismiss plaintiff complaint for failure to provide discovery. I make this Certification based upon personal knowledge and my review of the file materials herein. 2. The defendant filed an Answer to the Complaint on or about September 12, 2022 and pursuant to R. 4:17-1(b)(2), the plaintiff was deemed to have been served with interrogatories. In addition, we served the plaintiff with supplemental interrogatories by letter dated September 12, 2022 attached hereto as Exhibit A. The Rule requires that the plaintiff provide answers to those interrogatories within 30 days of the service of the defendant’s Answer. 3. More than thirty days has passed and, to date, we have not received answers to interrogatories from the plaintiff and they are now overdue. 4. By letter of October 10, 2022 attached hereto as Exhibit B, we have provided the plaintiff with notice that MON-L-001518-22 10/19/2022 2:21:40 PM Pg 5 of 10 Trans ID: LCV20223698120 they are in default in providing answers to Form A interrogatories and Supplemental Interrogatories and that the Complaint is subject to dismissal for this continuing non-compliance. 5. We now request that the plaintiff's Complaint be dismissed pursuant to R. 4:23-5(a)(1). 6. We are not in default in providing discovery. 7. There is a case management conference scheduled for October 27, 2022. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. _________________________________________ PATRICIA B. ADAMS, ESQ. Dated: 10/19 /2022 MON-L-001518-22 10/19/2022 2:21:40 PM Pg 6 of 10 Trans ID: LCV20223698120 EXHIBIT A MON-L-001518-22 10/19/2022 2:21:40 PM Pg 7 of 10 Trans ID: LCV20223698120 MON-L-001518-22 10/19/2022 2:21:40 PM Pg 8 of 10 Trans ID: LCV20223698120 MON-L-001518-22 10/19/2022 2:21:40 PM Pg 9 of 10 Trans ID: LCV20223698120 EXHIBIT B MON-L-001518-22 10/19/2022 2:21:40 PM Pg 10 of 10 Trans ID: LCV20223698120 LAW OFFICES CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. STEPHEN J. FOLEY, JR. ——— RALPH W. CAMPBELL MARIO J. DELANO § 1599 HIGHWAY 34, BLDG. E (1952-1993) PATRICIA B. ADAMS P.O. BOX 1570 JOHN J. LEE LEWIS M. MARKOWITZ WALL, N.J. 07719-1570 (1950-2001) SUSAN FOX BRENNAN MICHAEL J. CERNIGLIARO STEPHEN CZESLOWSKI □ TELE 732-775-6520 (1963-2011) HELEN A. CUMMINGS ——— FRANCIS J. MURPHY CHRISTIAN E. SCHLEGEL▲ GENERAL/CALENDAR FAX 732-869-2893 (1953-2012) STEPHEN J. FOLEY Certified by the Supreme Court ——— of New Jersey as a Civil Trial Attorney (1954-2015) E-MAIL: Admitted to the U.S.Supreme Court PADAMS@CAMPBELLFOLEY.COM § NJ & PA BAR □ NJ & NY BAR ▲ NJ, DC & VA BAR October 10, 2022 Evan D. Baker, Esq. Davis, Saperstein & Salomon, P.C. 375 Cedar Lane Teaneck, NJ 07666-3433 Re: Case v. NJM Docket No. MON-L-1518-19 File No. 41-40,455-PBA Dear Mr. Baker: By letter dated September 12, 2022, we requested certain discovery from your client, namely, answers to interrogatories and supplemental answers to interrogatories. You have failed to comply with our request. Please consider this letter your notice under R. 1:6-2(c). Your continuing non-compliance with our discovery request will result in our filing a motion to dismiss the plaintiff's Complaint under R. 4:23-5 WITHOUT FURTHER NOTICE TO YOUR OFFICE. Very truly yours, PATRICIA B. ADAMS, ESQ. PBA/cl MON-L-001518-22 10/19/2022 2:21:40 PM Pg 1 of 1 Trans ID: LCV20223698120 CAMPBELL, FOLEY, DELANO & ADAMS, L.L.C. PATRICIA B. ADAMS, ESQ. 014321995 1599 HWY 34, BLDG. E. P. O. Box 1570 WALL, NEW JERSEY 07719-1570 Telephone: (732) 775-6520 Attorneys for Defendant, NJM Our File No. 41-40,455-PBA ___________________________________________ Plaintiff, SUPERIOR COURT OF NEW JERSEY MARC CASE LAW DIVISION: MONMOUTH COUNTY DOCKET NO: MON-L-1518-22 vs. CIVIL ACTION Defendants, NEW JERSEY MANUFACTURERS INSURANCE ORDER TO DISMISS PLAINTIFF COMPLAINT FOR COMPANY, JOHN DOES 1-10 (FICTITIOUS NAMES FAILURE TO PROVIDE DISCOVERY REPRESENTING UNKNOWN INDIVIDUALS) AND/OR XYZ CORPS. 1-10 (FICTITIOUS NAMES REPRESENTING UNKNOWN CORPORATIONS, PARTNERSHIPS AND/OR LIMITED LIABILITY COMPANIES OR OTHER TYPES OF LEGAL ENTITIES) The above entitled matter having been opened to the Court on November 4, 2022, by Campbell, Foley, Delano & Adams, L.L.C., attorneys for the defendant, New Jersey Manufacturers Ins. Co., on motion to dismiss plaintiff complaint for failure to provide discovery, and it appearing to the satisfaction of the Court that the motion may be granted, it is hereby ORDERED on this day of , 2022, that the Complaint be and is hereby dismissed for failure of the plaintiff, Marc Case, to provide answers to Form A interrogatories and Supplemental Interrogatories, and it is further ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. Pursuant to Rule 1:5-1(a), movant shall serve a copy of this Order on all parties not served electronically within seven days of the date of this Order. _____________________________________ J.S.C. ( )Opposed ( )Unopposed