Preview
MID-L-000369-23 01/20/2023 3:59:59 PM Pglof8 Trans ID: LCV2023325305
Attorney ID # 000142007
PaLmisano & GoopMan, P.A.
171 Main Street
P.O. Box 518
Woodbridge, New Jersey 07095-0518
(732) 634-6464
Attorneys for Plaintiff
' SUPERIOR COURT OF NEW JERSEY
VALERIE M. YURCHAK, | LAW DIVISION: MIDDLESEX COUNTY
| DOCKET NO.
Plaintiff,
CIVIL ACTION
VS.
EDGAR A. MARROQUIN-CASTILLO,
“JOHN DOES #1-10”, “ABC COMPLAINT & JURY DEMAND
CORPORATION #1-10”, “ABC BAR,” “DEF
BAR,” “GHI BAR,” “RICHARD ROE #1-10”,
“JANE DOE #1-10” and “JAMES DOE #1-10
(names being fictitious as true identities are
unknown) and NEW JERSEY
MANUFACTURER’S INSURANCE
COMPANY,
Defendants
Plaintiff, Valerie M. Yurchak, residing at 77 West 36" Street in the City of Bayonne, County
of Hudson and State of New Jersey, complaining against defendant herein says:
FIRST COUNT
1 On or about October 22, 2021, plaintiff, Valerie M. Yurchak was a passenger in a
motor vehicle owned and operated by Stephen M. Yurchak, which was proceeding in an easterly
direction on Route 10 in the Township of Parsippany-Troy Hills, County of Morris and State of
New Jersey.
oe
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2. At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo
was the owner and operator of a motor vehicle, which motor vehicle was proceeding in an easterly
direction on Route 10 in the Township of Parsippany-Troy Hills, County of Morris and State of
New Jersey.
3 At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo,
so negligently operated his motor vehicle so as to cause a collision to occur with the vehicle plaintiff
was traveling in.
4 As a result of the aforesaid negligence of the defendant, plaintiff, Valerie M.
Yurchak, sustained severe personal injuries and other diverse damages.
5 Plaintiff has met the applicable threshold limit pursuant to N.J.S.A. 39:6A-8.
WHEREFORE, plaintiff, Valerie M. Yurchak, demands judgment against the defendant,
for damages and costs of suit and other relief the Court deems appropriate.
SECOND COUNT
1 Plaintiff, Valerie M. Yurchak, hereby repeats and reiterates each and every
allegation of the First Count as if the same were set forth herein at length.
2. Defendants, “JOHN DOES 1-10”, “ABC CORPORATION 1-10”, “ABC BAR”,
“DEF BAR”, “GHI BAR” and “RICHARD DOE #1-5” (names being fictitious as true identities are
unknown) were authorized to do business in the State of New Jersey and were the owners, holders
and/or licensees of a liquor license where alcoholic beverages were sold.
3 On October 22, 2021, the defendant, Edgar A. Marroquin-Castillo, indulged in the
drinking of alcoholic beverages at the premises of defendants, “ABC BAR”, “DEF BAR” and/or
“GHI BAR” (names being fictitious as true identities are unknown). Said alcoholic beverages were
sold and served to the defendant, Edgar A. Marroquin-Castillo, by agents, servants and/or
2
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employees of defendants, “ABC BAR”, “DEF BAR” and/or “GHI BAR” (names being fictitious as
true identities are unknown) and/or by “RICHARD DOE #1-5” (names being fictitious as true
identities are unknown) including “JANE DOES #1-5” and “JAMES DOE #1-5” (names being
fictitious as true identities are unknown) the managers, bartenders and/or servers of the
establishment on duty.
4 The defendants aforesaid individually and through their managers, bartenders,
servers, agents, servants and/or employees illegally, unlawfully, negligently and carelessly caused,
and permitted defendant, Edgar A. Marroquin-Castillo, to become visibly intoxicated while on their
premises, served the defendant while visibly intoxicated and thereupon permitted the defendant to
leave said premises in a visibly intoxicated state.
5 Defendant, Edgar A. Marroquin-Castillo, did operate his motor vehicle in an
intoxicated state and was involved in a collision involving said automobile.
6. The sale and service of the alcoholic beverages to the defendant, Edgar A.
Marroquin-Castillo, as stated aforesaid, rendered said defendant unable to properly operate and
control his vehicle, rendered him to be intoxicated and directly and proximately caused the plaintiff
to sustain serious and permanent injuries and other diverse damages.
7 For the reasons stated aforesaid, the defendants, Edgar A. Marroquin-Castillo and/or
“ABC BAR”, “DEF BAR” and/or “GHI BAR” and/or by “RICHARD DOE #1-5” (names being
fictitious as true identities are unknown) individually and through their managers, bartenders and/or
servers “JANE DOE #1-5” and “JAMES DOE #1-5” and their agents, servants, and/or employees
acted illegally, unlawfully, negligently and carelessly which conduct directly and proximately
caused the plaintiff to sustain serious and permanent injuries and other diverse damages, when the
MID-L-000369-23 01/20/2023 3:59:59 PM Pg4of8 Trans ID: LCV2023325305
defendant, while operating his motor vehicle in an intoxicated condition caused a collision to occur
as aforesaid.
WHEREFORE, plaintiff demands judgment against the defendants, jointly, severally,
individually, and/or vicariously for damages, interest and costs of suit.
THIRD COUNT
1 Plaintiff, Valerie M. Yurchak, hereby repeats each and every allegation of the First
Count and Second Counts as if the same were set forth in length.
2. At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo
was a lawful business invitee on the premises of “ABC BAR”, “DEF BAR”, “GHI BAR” and
“RICHARD DOE #1-5” (names being fictitious as true identities are unknown)
3 The defendants, “ABC BAR”, “DEF BAR”, “GHI BAR” and “RICHARD DOE #1-
5” (names being fictitious as true identities are unknown) jointly, individually and/or severally by
and through their agents, servants and/or employees did own, control, supervise, lease and/or
maintain the premises whereupon defendant, Edgar A. Marroquin-Castillo consumed alcoholic
beverages.
4 The actions of the defendants as aforesaid were performed negligently and carelessly
and as a result of which defendant, Edgar A. Marroquin-Castillo, was permitted to leave the subject
premises causing the subject motor vehicle accident in which the plaintiff, Valerie M. Yurchak
sustained severe, permanent injuries and other diverse damages.
WHEREFORE, plaintiff demands judgment against the defendants, jointly, severally,
individually, and/or vicariously for damages, interest and costs of suit.
FOURTH COUNT
1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second
4
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and Third Counts as if the same were more fully set forth herein and made a part hereof.
2 On October 22, 2021, defendants JOHN DOES #6-10 (names being fictitious as true
identities are unknown) owned and/or occupied the premises where defendant, Edgar A. Marroquin-
Castillo attended a social gathering.
3 At that gathering defendants JOHN DOES #6-10 (names being fictitious as true
identities are unknown), individually and/or through their agents, servants, and/or employees,
negligently, carelessly, and recklessly provided alcoholic beverages to defendant, Edgar A.
Marroquin-Castillo while he was visibly intoxicated and permitted him to leave said premises in
a visibly intoxicated state when it was reasonably foresseable that he would operate a motor
vehicle.
4 As a result of the negligence and carelessness of the defendants, JOHN DOES #6-
10, plaintiff did operate his motor vehicle in an intoxicated state and was involved in a collision
with the plaintiff.
5 As a direct and proximate result of the defendants’ carelessness and negligence,
plaintiff sustained severe personal injuries and other diverse damages.
WHEREFORE, plaintiff demands judgment against defendants jointly, severally or in the
alternative for damages and costs of suit.
FIFTH COUNT
1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second,
Third and Fourth Counts as if the same were more fully set forth herein and made a part hereof.
2. Defendant, Edgar A. Marroquin-Castillo’s conduct, which was wilful, wanton,
reckless and intentional, contributed to the occurrence of the accident of October 22, 2021.
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3 By reason of this conduct, the plaintiff, Valerie M. Yurchak was caused to be injured
and suffer injuries; she was caused to suffer great pain and will in the future be caused to suffer great
pain; she was caused to incur medical expenses and will in the future be caused to incur medical
expenses; she was caused to lose time from her employment and will in the future be caused to lose
time from her employment; she was caused to suffer permanent injuries.
WHEREFORE, the plaintiff, Valerie M. Yurchak demands judgment against the defendant,
Edgar A. Marroquin-Castillo on this Count for PUNITIVE DAMAGES.
SIXTH COUNT
1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second,
Third, Fourth and Fifth Counts as if the same were more fully set forth herein and made a part
hereof.
2 Upon information and belief, the defendant, Edgar A. Marroquin-Castillo
was insured with Progressive Insurance Company and maintained a $15,000/$30,000 policy of
insurance.
3 At all times hereinafter mentioned, the plaintiff was insured by defendant, New
Jersey Manufacturer’s Insurance Company (who is authorized to do business in Middlesex
County) under policy # F10092564-3 with uninsured/underinsured motorist benefits by reason
providing $300,000 CSL in coverage to plaintiff.
4 The above-mentioned owner of said underinsured vehicle negligently and
carelessly owned and operated his aforesaid vehicle in a dangerous manner striking the vehicle
plaintiff was traveling in and in violation of the law. As a result, plaintiff, Edgar A. Marroquin-
Castillo sustained severe personal injuries and other diverse damages.
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5 As a result of the negligence as aforestated of the underinsured vehicle which
bears liability for the happening of this accident, plaintiff is entitled to compensation under the
uninsured/underinsured motorist coverage from New Jersey Manufacturer’s Insurance Company
6 Plaintiff has met the applicable threshold limit pursuant to N.J.S.A. 39:6A-8.
WHEREFORE, plaintiff demands judgment against defendant, New Jersey
Manufacturer’s Insurance Company, for:
(a) A jury trial pursuant to the policy of insurance;
(b) Damages and costs of suit;
©) Uninsured/underinsured coverage under New Jersey Manufacturer’s Insurance
Company’s policy of insurance;
@ Counsel fees and costs;
(e) Any other relief which the Court deems fair and just.
JURY DEMAND
Plaintiff demands a trial by jury on all issues.
CERTIFICATION PER R. 4:5-1
Thereby certify, R. 1:4-4(b) that the matter in controversy is not the subject of any other
action pending in any court or of a pending arbitration proceeding and none are contemplated.
I further certify that this pleading contains no personal confidential identifiers. I
understand it is my responsibility to ensure there will be no personal confidential identifiers in
any subsequent pleadings filed.
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.
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DESIGNATION OF TRIAL COUNSEL PURSUANT TO RULE 4:25-4
Robert G. Goodman, Esq. of the firm of Palmisano & Goodman, P.A., attorneys for the
aforementioned plaintiff is hereby designated as trial counsel in the within matter.
PALMISANO & GOODMAN, P.A.
Attorneys for Plaintiff
BY: AAL—
GREGORY G. GOODMAN, ESQ.
Dated: January 20, 2023
MID-L-000369-23 01/20/2023 3:59:59 PM Pglof1 Trans ID: LCV2023325305
Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-000369-23
Case Caption: YURCHAK VALERIE VS MARROQUIN- Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
CASTILLO EDGAR THRESHOLD)
Case Initiation Date: 01/20/2023 Document Type: Complaint with Jury Demand
Attorney Name: GREGORY G GOODMAN Jury Demand: YES - 6 JURORS
Firm Name: PALMISANO & GOODMAN P.A. Is this a professional malpractice case? NO
Address: 171 MAIN STREET Related cases pending: NO
WOODBRIDGE NJ 07095 If yes, list docket numbers:
Phone: 7326346464 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Yurchak, Valerie, M transaction or occurrence)? NO
Name of Defendant's Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): Progressive
Are sexual abuse claims alleged by: Valerie M Yurchak? 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
| 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)
01/20/2023 /s|/ GREGORY G GOODMAN
Dated Signed
Preview
MID-L-000369-23 01/20/2023 3:59:59 PM Pglof8 Trans ID: LCV2023325305 Attorney ID # 000142007 PaLmisano & GoopMan, P.A. 171 Main Street P.O. Box 518 Woodbridge, New Jersey 07095-0518 (732) 634-6464 Attorneys for Plaintiff ' SUPERIOR COURT OF NEW JERSEY VALERIE M. YURCHAK, | LAW DIVISION: MIDDLESEX COUNTY | DOCKET NO. Plaintiff, CIVIL ACTION VS. EDGAR A. MARROQUIN-CASTILLO, “JOHN DOES #1-10”, “ABC COMPLAINT & JURY DEMAND CORPORATION #1-10”, “ABC BAR,” “DEF BAR,” “GHI BAR,” “RICHARD ROE #1-10”, “JANE DOE #1-10” and “JAMES DOE #1-10 (names being fictitious as true identities are unknown) and NEW JERSEY MANUFACTURER’S INSURANCE COMPANY, Defendants Plaintiff, Valerie M. Yurchak, residing at 77 West 36" Street in the City of Bayonne, County of Hudson and State of New Jersey, complaining against defendant herein says: FIRST COUNT 1 On or about October 22, 2021, plaintiff, Valerie M. Yurchak was a passenger in a motor vehicle owned and operated by Stephen M. Yurchak, which was proceeding in an easterly direction on Route 10 in the Township of Parsippany-Troy Hills, County of Morris and State of New Jersey. oe MID-L-000369-23 01/20/2023 3:59:59 PM Pg2of8 Trans ID: LCV2023325305 2. At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo was the owner and operator of a motor vehicle, which motor vehicle was proceeding in an easterly direction on Route 10 in the Township of Parsippany-Troy Hills, County of Morris and State of New Jersey. 3 At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo, so negligently operated his motor vehicle so as to cause a collision to occur with the vehicle plaintiff was traveling in. 4 As a result of the aforesaid negligence of the defendant, plaintiff, Valerie M. Yurchak, sustained severe personal injuries and other diverse damages. 5 Plaintiff has met the applicable threshold limit pursuant to N.J.S.A. 39:6A-8. WHEREFORE, plaintiff, Valerie M. Yurchak, demands judgment against the defendant, for damages and costs of suit and other relief the Court deems appropriate. SECOND COUNT 1 Plaintiff, Valerie M. Yurchak, hereby repeats and reiterates each and every allegation of the First Count as if the same were set forth herein at length. 2. Defendants, “JOHN DOES 1-10”, “ABC CORPORATION 1-10”, “ABC BAR”, “DEF BAR”, “GHI BAR” and “RICHARD DOE #1-5” (names being fictitious as true identities are unknown) were authorized to do business in the State of New Jersey and were the owners, holders and/or licensees of a liquor license where alcoholic beverages were sold. 3 On October 22, 2021, the defendant, Edgar A. Marroquin-Castillo, indulged in the drinking of alcoholic beverages at the premises of defendants, “ABC BAR”, “DEF BAR” and/or “GHI BAR” (names being fictitious as true identities are unknown). Said alcoholic beverages were sold and served to the defendant, Edgar A. Marroquin-Castillo, by agents, servants and/or 2 MID-L-000369-23 01/20/2023 3:59:59 PM Pg3of8 Trans ID: LCV2023325305 employees of defendants, “ABC BAR”, “DEF BAR” and/or “GHI BAR” (names being fictitious as true identities are unknown) and/or by “RICHARD DOE #1-5” (names being fictitious as true identities are unknown) including “JANE DOES #1-5” and “JAMES DOE #1-5” (names being fictitious as true identities are unknown) the managers, bartenders and/or servers of the establishment on duty. 4 The defendants aforesaid individually and through their managers, bartenders, servers, agents, servants and/or employees illegally, unlawfully, negligently and carelessly caused, and permitted defendant, Edgar A. Marroquin-Castillo, to become visibly intoxicated while on their premises, served the defendant while visibly intoxicated and thereupon permitted the defendant to leave said premises in a visibly intoxicated state. 5 Defendant, Edgar A. Marroquin-Castillo, did operate his motor vehicle in an intoxicated state and was involved in a collision involving said automobile. 6. The sale and service of the alcoholic beverages to the defendant, Edgar A. Marroquin-Castillo, as stated aforesaid, rendered said defendant unable to properly operate and control his vehicle, rendered him to be intoxicated and directly and proximately caused the plaintiff to sustain serious and permanent injuries and other diverse damages. 7 For the reasons stated aforesaid, the defendants, Edgar A. Marroquin-Castillo and/or “ABC BAR”, “DEF BAR” and/or “GHI BAR” and/or by “RICHARD DOE #1-5” (names being fictitious as true identities are unknown) individually and through their managers, bartenders and/or servers “JANE DOE #1-5” and “JAMES DOE #1-5” and their agents, servants, and/or employees acted illegally, unlawfully, negligently and carelessly which conduct directly and proximately caused the plaintiff to sustain serious and permanent injuries and other diverse damages, when the MID-L-000369-23 01/20/2023 3:59:59 PM Pg4of8 Trans ID: LCV2023325305 defendant, while operating his motor vehicle in an intoxicated condition caused a collision to occur as aforesaid. WHEREFORE, plaintiff demands judgment against the defendants, jointly, severally, individually, and/or vicariously for damages, interest and costs of suit. THIRD COUNT 1 Plaintiff, Valerie M. Yurchak, hereby repeats each and every allegation of the First Count and Second Counts as if the same were set forth in length. 2. At the same time and place aforesaid, the defendant, Edgar A. Marroquin-Castillo was a lawful business invitee on the premises of “ABC BAR”, “DEF BAR”, “GHI BAR” and “RICHARD DOE #1-5” (names being fictitious as true identities are unknown) 3 The defendants, “ABC BAR”, “DEF BAR”, “GHI BAR” and “RICHARD DOE #1- 5” (names being fictitious as true identities are unknown) jointly, individually and/or severally by and through their agents, servants and/or employees did own, control, supervise, lease and/or maintain the premises whereupon defendant, Edgar A. Marroquin-Castillo consumed alcoholic beverages. 4 The actions of the defendants as aforesaid were performed negligently and carelessly and as a result of which defendant, Edgar A. Marroquin-Castillo, was permitted to leave the subject premises causing the subject motor vehicle accident in which the plaintiff, Valerie M. Yurchak sustained severe, permanent injuries and other diverse damages. WHEREFORE, plaintiff demands judgment against the defendants, jointly, severally, individually, and/or vicariously for damages, interest and costs of suit. FOURTH COUNT 1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second 4 MID-L-000369-23 01/20/2023 3:59:59 PM Pg5of8 Trans ID: LCV2023325305 and Third Counts as if the same were more fully set forth herein and made a part hereof. 2 On October 22, 2021, defendants JOHN DOES #6-10 (names being fictitious as true identities are unknown) owned and/or occupied the premises where defendant, Edgar A. Marroquin- Castillo attended a social gathering. 3 At that gathering defendants JOHN DOES #6-10 (names being fictitious as true identities are unknown), individually and/or through their agents, servants, and/or employees, negligently, carelessly, and recklessly provided alcoholic beverages to defendant, Edgar A. Marroquin-Castillo while he was visibly intoxicated and permitted him to leave said premises in a visibly intoxicated state when it was reasonably foresseable that he would operate a motor vehicle. 4 As a result of the negligence and carelessness of the defendants, JOHN DOES #6- 10, plaintiff did operate his motor vehicle in an intoxicated state and was involved in a collision with the plaintiff. 5 As a direct and proximate result of the defendants’ carelessness and negligence, plaintiff sustained severe personal injuries and other diverse damages. WHEREFORE, plaintiff demands judgment against defendants jointly, severally or in the alternative for damages and costs of suit. FIFTH COUNT 1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second, Third and Fourth Counts as if the same were more fully set forth herein and made a part hereof. 2. Defendant, Edgar A. Marroquin-Castillo’s conduct, which was wilful, wanton, reckless and intentional, contributed to the occurrence of the accident of October 22, 2021. MID-L-000369-23 01/20/2023 3:59:59 PM Pg6of8 Trans ID: LCV2023325305 3 By reason of this conduct, the plaintiff, Valerie M. Yurchak was caused to be injured and suffer injuries; she was caused to suffer great pain and will in the future be caused to suffer great pain; she was caused to incur medical expenses and will in the future be caused to incur medical expenses; she was caused to lose time from her employment and will in the future be caused to lose time from her employment; she was caused to suffer permanent injuries. WHEREFORE, the plaintiff, Valerie M. Yurchak demands judgment against the defendant, Edgar A. Marroquin-Castillo on this Count for PUNITIVE DAMAGES. SIXTH COUNT 1 Plaintiff, Valerie M. Yurchak, repeats the allegations contained in the First, Second, Third, Fourth and Fifth Counts as if the same were more fully set forth herein and made a part hereof. 2 Upon information and belief, the defendant, Edgar A. Marroquin-Castillo was insured with Progressive Insurance Company and maintained a $15,000/$30,000 policy of insurance. 3 At all times hereinafter mentioned, the plaintiff was insured by defendant, New Jersey Manufacturer’s Insurance Company (who is authorized to do business in Middlesex County) under policy # F10092564-3 with uninsured/underinsured motorist benefits by reason providing $300,000 CSL in coverage to plaintiff. 4 The above-mentioned owner of said underinsured vehicle negligently and carelessly owned and operated his aforesaid vehicle in a dangerous manner striking the vehicle plaintiff was traveling in and in violation of the law. As a result, plaintiff, Edgar A. Marroquin- Castillo sustained severe personal injuries and other diverse damages. MID-L-000369-23 01/20/2023 3:59:59 PM Pg7of8 Trans ID: LCV2023325305 5 As a result of the negligence as aforestated of the underinsured vehicle which bears liability for the happening of this accident, plaintiff is entitled to compensation under the uninsured/underinsured motorist coverage from New Jersey Manufacturer’s Insurance Company 6 Plaintiff has met the applicable threshold limit pursuant to N.J.S.A. 39:6A-8. WHEREFORE, plaintiff demands judgment against defendant, New Jersey Manufacturer’s Insurance Company, for: (a) A jury trial pursuant to the policy of insurance; (b) Damages and costs of suit; ©) Uninsured/underinsured coverage under New Jersey Manufacturer’s Insurance Company’s policy of insurance; @ Counsel fees and costs; (e) Any other relief which the Court deems fair and just. JURY DEMAND Plaintiff demands a trial by jury on all issues. CERTIFICATION PER R. 4:5-1 Thereby certify, R. 1:4-4(b) that the matter in controversy is not the subject of any other action pending in any court or of a pending arbitration proceeding and none are contemplated. I further certify that this pleading contains no personal confidential identifiers. I understand it is my responsibility to ensure there will be no personal confidential identifiers in any subsequent pleadings filed. 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. MID-L-000369-23 01/20/2023 3:59:59 PM Pg 8of8 Trans ID: LCV2023325305 DESIGNATION OF TRIAL COUNSEL PURSUANT TO RULE 4:25-4 Robert G. Goodman, Esq. of the firm of Palmisano & Goodman, P.A., attorneys for the aforementioned plaintiff is hereby designated as trial counsel in the within matter. PALMISANO & GOODMAN, P.A. Attorneys for Plaintiff BY: AAL— GREGORY G. GOODMAN, ESQ. Dated: January 20, 2023 MID-L-000369-23 01/20/2023 3:59:59 PM Pglof1 Trans ID: LCV2023325305 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-000369-23 Case Caption: YURCHAK VALERIE VS MARROQUIN- Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL CASTILLO EDGAR THRESHOLD) Case Initiation Date: 01/20/2023 Document Type: Complaint with Jury Demand Attorney Name: GREGORY G GOODMAN Jury Demand: YES - 6 JURORS Firm Name: PALMISANO & GOODMAN P.A. Is this a professional malpractice case? NO Address: 171 MAIN STREET Related cases pending: NO WOODBRIDGE NJ 07095 If yes, list docket numbers: Phone: 7326346464 Do you anticipate adding any parties (arising out of same Name of Party: PLAINTIFF : Yurchak, Valerie, M transaction or occurrence)? NO Name of Defendant's Primary Insurance Company Does this case involve claims related to COVID-19? NO (if known): Progressive Are sexual abuse claims alleged by: Valerie M Yurchak? 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 | 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) 01/20/2023 /s|/ GREGORY G GOODMAN Dated Signed