Preview
MID-L-002942-23 05/24/2023 5:12:27 PM Pg 1 of 8 Trans ID: LCV20231633631
PATRICK F. KELLY, ESQ. 307002020
GINARTE GONZALEZ WINOGRAD, L.L.P.
400 MARKET STREET
NEWARK, NEW JERSEY 07105
(973)854-8400
Our File No.: 265589
Attorneys for Plaintiff, Julia Miranda DePineda
JULIA MIRANDA DEPINEDA, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: MIDDLESEX COUNTY
Plaintiff, : DOCKET NO.: MID-L-
:
vs. : CIVIL ACTION
:
ISMAEL JUAREZ-MARTINEZ, : COMPLAINT, JURY DEMAND,
SORIANO P LANDSCAPING LLC, : DESIGNATION OF TRIAL COUNSEL,
JOHN and JANE DOES 1-10 (fictitious : DISCOVERY REQUESTS UPON
unidentified individuals) AND ABC : DEFENDANTS, AND REQUEST FOR
CORPORATIONS 1-10, (fictitious : ADMISSIONS
individuals, corporations or other business :
entities presently unidentifiable) :
:
Defendants.
Plaintiff, JULIA MIRANDA DEPINEDA, residing at 198 Talmadge Avenue, Apt 2, in the
city/town of New Brunswick, County of Middlesex and State of New Jersey, complaining of the
Defendants, deposes and says:
FIRST COUNT
1. On or about June 1, 2021, Plaintiff Julia Miranda DePineda was the owner and operator
of a motor vehicle, and which motor vehicle was traveling east on Handy Street at or near its
intersection with Joycekilmer Avenue in New Brunswick, New Jersey.
2. At the same place and at the same time, Defendant Ismael Juarez-Martinez was the
operator of a motor vehicle owned by Defendant Soriano P Landscaping LLC and which motor vehicle
was attempting to make a right turn onto Joycekilmer Avenue from Handy Street causing the trailer
attached to the motor vehicle to strike Plaintiff’s vehicle.
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3. Defendants, John and Jane Does 1-10 and ABC Corporations 1-10, are theretofore
unidentified individuals and business entities named herein for the express purpose of tolling the
applicable statute of limitations.
4. On the above-mentioned date and the above-mentioned place, Defendants did so
negligently and carelessly own, operate, negligently entrust and/or maintain their motor vehicle so as to
cause same to be involved in a collision with the vehicle that was occupied by Plaintiff, Julia Miranda
DePineda.
5. As a direct and proximate result of the negligence of Defendants, as aforesaid, Plaintiff,
Julia Miranda DePineda, was caused to sustain and did sustain serious and permanent personal injuries
requiring the care and treatment of physicians, hospitalization and medication and has been and will in
the future continue to be hampered in their daily routine.
6. This action is not barred by N.J.S.A. 39:6A-1, et seq.
WHEREFORE, Plaintiff, Julia Miranda DePineda, demands judgment against the Defendants
in the amount of her damages together with interest and costs of suit.
SECOND COUNT
1. Plaintiff repeats and re-alleges the allegations of the prior Count as though set forth at
length herein.
2. Defendants, John and Jane Does 1-10 and ABC Corporations 1-10, are theretofore un-
identified individuals and business entities named herein for the express purpose of tolling the applicable
statute of limitations.
3. On the same date, Defendants carelessly, recklessly and negligently caused a motor
vehicle to strike the plaintiff’s motor vehicle.
4. As a direct and proximate result of the negligence of these Defendants, as aforesaid,
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Plaintiff, Julia Miranda DePineda, was caused to sustain and did sustain serious and permanent personal
injuries requiring the care and treatment of physicians, hospitalization and medication and has been and
will in the future continue to be hampered in her daily routine, was and will be required to curtail their
usual activities and pursuits, and has and will incur lost wages and medical expenses.
5. This action is not barred by N.J. Stat. 39:6A-1, et seq.
WHEREFORE, Plaintiff, Julia Miranda DePineda, demands judgment against the Defendants
in the amount of her damages together with interest and costs of suit.
JURY DEMAND
Plaintiff demands a trial by jury of all issues so triable.
GINARTE GONZALEZ WINOGRAD, L.L.P.
Attorneys for Plaintiff
/s/ Patrick F. Kelly
BY:________________________________
PATRICK F. KELLY, ESQ.
DATED: May 24, 2023
CERTIFICATION
I hereby certify that the within action is not the subject of any other action or arbitration
proceeding nor is any contemplated.
GINARTE GONZALEZ WINOGRAD, L.L.P.
Attorneys for Plaintiff
/s/ Patrick F. Kelly
BY:________________________________
PATRICK F. KELLY, ESQ.
DATED: May 24, 2023
DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4:25-4, the firm of Ginarte Gallardo Gonzalez & Winograd, L.L.P. attorneys
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for Plaintiff, hereby appoint PATRICK F. KELLY, ESQ. as trial counsel.
GINARTE GONZALEZ WINOGRAD, L.L.P.
Attorneys for Plaintiff
/s/ Patrick F. Kelly
BY:________________________________
PATRICK F. KELLY, ESQ.
DATED: May 24, 2023
DEMAND FOR ANSWERS TO INTERROGATORIES
Pursuant to Rule 4:17-1 et seq., Plaintiff hereby demands that Defendants provide answers to
Form C and C-1 interrogatories within the timeframes prescribed by the New Jersey Rules of Court.
DEMAND FOR ANSWERS TO SUPPLEMENTAL INTERROGATORIES
Pursuant to Rule 4:17-1 et seq., Plaintiff hereby demands that all defendants provide answers to
the following supplemental interrogatories.
1. State where you were coming from immediately prior to the incident and what your
intended destination was.
2. State whether you observed the plaintiff or plaintiff’s vehicle prior to the collision. If
yes, state the approximate speed of each vehicle/person; where you were at the time you first observed
the other vehicle/person; the distance between you and the other vehicle/person at the first moment
you observed the other vehicle/person; and the amount of time that passed from the time of your first
observation to the time of the impact.
3. Provide the name and address of any individuals or entities that you allege are
responsible, to any degree, for the subject accident or plaintiff’s alleged injuries. Please describe how
you believe those individuals or entities are responsible.
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DEMAND FOR PRODUCTION OF DOCUMENTS
Pursuant to Rule 4:18-1, et seq., Plaintiff hereby demands that Defendants provide the following
documents within the times prescribed by the New Jersey Rules of Court:
1. Any and all statements or reports made by any person or governmental entity concerning
this civil action or its subject matter.
2. Copies of any and all photographs in your possession of the vehicles, the location, or the
parties involved in this accident.
3. Copies of any and all repairs estimates of the vehicles involved in this accident.
4. Copies of any claims information bureau or other insurance claims searches or other
documents referencing any prior or subsequent injuries and/or claims by the plaintiff.
5. Copies of any statements made by any person with regard to the happening of the
collision or having to do with the subject matter of this action.
6. Copies of any and all expert reports, reports of diagnostic tests, hospital and medical
records, X-rays, CAT scan films, MRI films and any other films and bills relating to any condition or
injury sustained by the plaintiff.
7. Copies of all written reports or summaries of oral reports of all expert(s) or treating or
examining physician(s) along with their curriculum vitae.
8. Copies of any and all books, treatises, commentaries, reports, statutes, codes, ordinances,
rules, regulations or other published documents referred to, utilized by or relied upon by any expert
witness whom plaintiff/defendant intends to call at the time of trial.
9. Copies of any and all documents, reports, correspondence, blue prints, charts, diagrams,
drawings, graphs, maps, plats, plans, photographs, models or other visual reproductions of any object,
place or thing prepared or utilized by, referred to or relied upon by any expert witnesses, whether or not
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you intend on calling them at the time of trial.
10. Copies of any and all photographs, diagrams, charts, drawings, maps, plans or models or
other visual reproductions of any object, place or thing related to this litigation.
11. All documents, tangible evidence or other items relevant to the incident set forth in the
Plaintiff’s Complaint.
12. All deeds, leases, contracts, invoices, maintenance agreements, or records pertaining to
any person, vehicle, or premises identified in the plaintiff’s complaint.
13. Copies of any documents provided to drivers as part of their training or orientation.
14. If you are not supplying any statement, report, medical record or other item requested
herein, identify the item; indicate who has possession of the item; specify their address and state the
reason why the items are not being provided.
15. Provide copies of all documents you intend to use at trial, including cross-examination
and for impeachment purposes.
16. Was any type of surveillance taken of the plaintiff and, if so, state the name, address and
occupation of the person performing such surveillance, the dates of this surveillance, and produce
copies of any and all surveillance materials along with logs and any other materials relating to the
surveillance.
17. Provide all videos and/or images and/or photographs and/or any depiction of the plaintiff.
18. Provide all videos and/or images and/or photographs and/or any depiction of the accident
scene and of the accident itself.
19. With respect to any expert of the defendant, provide:
i) a complete statement of all opinions the witness will express and the basis
and reasons for them:
ii) the date or other information considered by the witness in forming them;
iii) any exhibits that will be used to summarize or support them;
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iv) the witness’s qualifications, including a list of all publications authored in the
previous 10 years;
v) a list of all other cases in which, during the previous four years, the witness
testified as an expert at trial or by deposition;
vi) a statement of the compensation to be paid for the study and testimony in
this case.
REQUEST FOR ADMISSIONS
Pursuant to Rule 4:22-1, et seq., plaintiff hereby demands that all defendants provide the
following documents:
1. The incident that forms the basis of this action occurred on the date and at the place
referenced in the complaint.
2. You owned the vehicle attributed to you in the complaint at the time of the accident
described in the complaint.
3. You operated the vehicle attributed to you in the complaint at the time of the accident
described in the complaint.
4. Your vehicle was involved in the accident described in the complaint.
5. You were operating the vehicle referred to in statement number 3 above with the
permission of the owner.
6. You gave permission to operate the vehicle referred to in statement number 4 above to
the person operating it at the time of the subject accident.
7. The statements attributed to you in the crash description of the police report were made
by you.
8. The verbal threshold or lawsuit limitation does not apply since plaintiff’s and/or
defendants’ vehicles were commercial vehicles.
DEMAND FOR DISCOVERY OF INSURANCE COVERAGE
Pursuant to R. 4:10-2 (b) demand is hereby made that you disclose to the undersigned whether
there are any insurance agreements or policies under which any person or firm carrying on an insurance
business may be liable to satisfy part or all of a judgment which may be entered in this action or to
indemnify or reimburse for payments made to satisfy the judgment. If the answer is "yes" attach a copy
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of each or in the alternative state, under oath or certification (a) number (b) name and address of insurer
or issuer (c) inception and expiration dates (d) names and addresses of all persons insured thereunder (e)
personal injury limits (f) property damage limits (g) medical payment limits (h) name and address of
person who has custody and possession thereof (i) where and when each policy or agreement can be
inspected and copied., (j) excess coverage, (k) concurrent coverage, (l) umbrella policies.
GINARTE GONZALEZ WINOGRAD, L.L.P.
Attorneys for Plaintiff
/s/ Patrick F. Kelly
BY:________________________________
PATRICK F. KELLY, ESQ.
DATED: May 24, 2023
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Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-002942-23
Case Caption: MIRANDA DEPINEDA JULIA VS JUAREZ- Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
MARTINEZ ISMAEL VERBAL THRESHOLD)
Case Initiation Date: 05/24/2023 Document Type: Complaint with Jury Demand
Attorney Name: PATRICK KELLY Jury Demand: YES - 6 JURORS
Firm Name: GINARTE GALLARDO GONZALEZ Is this a professional malpractice case? NO
WINOGRAD, LLP Related cases pending: NO
Address: 400 MARKET ST If yes, list docket numbers:
NEWARK NJ 07105 Do you anticipate adding any parties (arising out of same
Phone: 9738548400 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Miranda DePineda, Julia Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): None Are sexual abuse claims alleged by: Julia Miranda DePineda? 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)
05/24/2023 /s/ PATRICK KELLY
Dated Signed
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Preview
MID-L-002942-23 05/24/2023 5:12:27 PM Pg 1 of 8 Trans ID: LCV20231633631 PATRICK F. KELLY, ESQ. 307002020 GINARTE GONZALEZ WINOGRAD, L.L.P. 400 MARKET STREET NEWARK, NEW JERSEY 07105 (973)854-8400 Our File No.: 265589 Attorneys for Plaintiff, Julia Miranda DePineda JULIA MIRANDA DEPINEDA, : SUPERIOR COURT OF NEW JERSEY : LAW DIVISION: MIDDLESEX COUNTY Plaintiff, : DOCKET NO.: MID-L- : vs. : CIVIL ACTION : ISMAEL JUAREZ-MARTINEZ, : COMPLAINT, JURY DEMAND, SORIANO P LANDSCAPING LLC, : DESIGNATION OF TRIAL COUNSEL, JOHN and JANE DOES 1-10 (fictitious : DISCOVERY REQUESTS UPON unidentified individuals) AND ABC : DEFENDANTS, AND REQUEST FOR CORPORATIONS 1-10, (fictitious : ADMISSIONS individuals, corporations or other business : entities presently unidentifiable) : : Defendants. Plaintiff, JULIA MIRANDA DEPINEDA, residing at 198 Talmadge Avenue, Apt 2, in the city/town of New Brunswick, County of Middlesex and State of New Jersey, complaining of the Defendants, deposes and says: FIRST COUNT 1. On or about June 1, 2021, Plaintiff Julia Miranda DePineda was the owner and operator of a motor vehicle, and which motor vehicle was traveling east on Handy Street at or near its intersection with Joycekilmer Avenue in New Brunswick, New Jersey. 2. At the same place and at the same time, Defendant Ismael Juarez-Martinez was the operator of a motor vehicle owned by Defendant Soriano P Landscaping LLC and which motor vehicle was attempting to make a right turn onto Joycekilmer Avenue from Handy Street causing the trailer attached to the motor vehicle to strike Plaintiff’s vehicle. 1 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 2 of 8 Trans ID: LCV20231633631 3. Defendants, John and Jane Does 1-10 and ABC Corporations 1-10, are theretofore unidentified individuals and business entities named herein for the express purpose of tolling the applicable statute of limitations. 4. On the above-mentioned date and the above-mentioned place, Defendants did so negligently and carelessly own, operate, negligently entrust and/or maintain their motor vehicle so as to cause same to be involved in a collision with the vehicle that was occupied by Plaintiff, Julia Miranda DePineda. 5. As a direct and proximate result of the negligence of Defendants, as aforesaid, Plaintiff, Julia Miranda DePineda, was caused to sustain and did sustain serious and permanent personal injuries requiring the care and treatment of physicians, hospitalization and medication and has been and will in the future continue to be hampered in their daily routine. 6. This action is not barred by N.J.S.A. 39:6A-1, et seq. WHEREFORE, Plaintiff, Julia Miranda DePineda, demands judgment against the Defendants in the amount of her damages together with interest and costs of suit. SECOND COUNT 1. Plaintiff repeats and re-alleges the allegations of the prior Count as though set forth at length herein. 2. Defendants, John and Jane Does 1-10 and ABC Corporations 1-10, are theretofore un- identified individuals and business entities named herein for the express purpose of tolling the applicable statute of limitations. 3. On the same date, Defendants carelessly, recklessly and negligently caused a motor vehicle to strike the plaintiff’s motor vehicle. 4. As a direct and proximate result of the negligence of these Defendants, as aforesaid, 2 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 3 of 8 Trans ID: LCV20231633631 Plaintiff, Julia Miranda DePineda, was caused to sustain and did sustain serious and permanent personal injuries requiring the care and treatment of physicians, hospitalization and medication and has been and will in the future continue to be hampered in her daily routine, was and will be required to curtail their usual activities and pursuits, and has and will incur lost wages and medical expenses. 5. This action is not barred by N.J. Stat. 39:6A-1, et seq. WHEREFORE, Plaintiff, Julia Miranda DePineda, demands judgment against the Defendants in the amount of her damages together with interest and costs of suit. JURY DEMAND Plaintiff demands a trial by jury of all issues so triable. GINARTE GONZALEZ WINOGRAD, L.L.P. Attorneys for Plaintiff /s/ Patrick F. Kelly BY:________________________________ PATRICK F. KELLY, ESQ. DATED: May 24, 2023 CERTIFICATION I hereby certify that the within action is not the subject of any other action or arbitration proceeding nor is any contemplated. GINARTE GONZALEZ WINOGRAD, L.L.P. Attorneys for Plaintiff /s/ Patrick F. Kelly BY:________________________________ PATRICK F. KELLY, ESQ. DATED: May 24, 2023 DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4:25-4, the firm of Ginarte Gallardo Gonzalez & Winograd, L.L.P. attorneys 3 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 4 of 8 Trans ID: LCV20231633631 for Plaintiff, hereby appoint PATRICK F. KELLY, ESQ. as trial counsel. GINARTE GONZALEZ WINOGRAD, L.L.P. Attorneys for Plaintiff /s/ Patrick F. Kelly BY:________________________________ PATRICK F. KELLY, ESQ. DATED: May 24, 2023 DEMAND FOR ANSWERS TO INTERROGATORIES Pursuant to Rule 4:17-1 et seq., Plaintiff hereby demands that Defendants provide answers to Form C and C-1 interrogatories within the timeframes prescribed by the New Jersey Rules of Court. DEMAND FOR ANSWERS TO SUPPLEMENTAL INTERROGATORIES Pursuant to Rule 4:17-1 et seq., Plaintiff hereby demands that all defendants provide answers to the following supplemental interrogatories. 1. State where you were coming from immediately prior to the incident and what your intended destination was. 2. State whether you observed the plaintiff or plaintiff’s vehicle prior to the collision. If yes, state the approximate speed of each vehicle/person; where you were at the time you first observed the other vehicle/person; the distance between you and the other vehicle/person at the first moment you observed the other vehicle/person; and the amount of time that passed from the time of your first observation to the time of the impact. 3. Provide the name and address of any individuals or entities that you allege are responsible, to any degree, for the subject accident or plaintiff’s alleged injuries. Please describe how you believe those individuals or entities are responsible. 4 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 5 of 8 Trans ID: LCV20231633631 DEMAND FOR PRODUCTION OF DOCUMENTS Pursuant to Rule 4:18-1, et seq., Plaintiff hereby demands that Defendants provide the following documents within the times prescribed by the New Jersey Rules of Court: 1. Any and all statements or reports made by any person or governmental entity concerning this civil action or its subject matter. 2. Copies of any and all photographs in your possession of the vehicles, the location, or the parties involved in this accident. 3. Copies of any and all repairs estimates of the vehicles involved in this accident. 4. Copies of any claims information bureau or other insurance claims searches or other documents referencing any prior or subsequent injuries and/or claims by the plaintiff. 5. Copies of any statements made by any person with regard to the happening of the collision or having to do with the subject matter of this action. 6. Copies of any and all expert reports, reports of diagnostic tests, hospital and medical records, X-rays, CAT scan films, MRI films and any other films and bills relating to any condition or injury sustained by the plaintiff. 7. Copies of all written reports or summaries of oral reports of all expert(s) or treating or examining physician(s) along with their curriculum vitae. 8. Copies of any and all books, treatises, commentaries, reports, statutes, codes, ordinances, rules, regulations or other published documents referred to, utilized by or relied upon by any expert witness whom plaintiff/defendant intends to call at the time of trial. 9. Copies of any and all documents, reports, correspondence, blue prints, charts, diagrams, drawings, graphs, maps, plats, plans, photographs, models or other visual reproductions of any object, place or thing prepared or utilized by, referred to or relied upon by any expert witnesses, whether or not 5 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 6 of 8 Trans ID: LCV20231633631 you intend on calling them at the time of trial. 10. Copies of any and all photographs, diagrams, charts, drawings, maps, plans or models or other visual reproductions of any object, place or thing related to this litigation. 11. All documents, tangible evidence or other items relevant to the incident set forth in the Plaintiff’s Complaint. 12. All deeds, leases, contracts, invoices, maintenance agreements, or records pertaining to any person, vehicle, or premises identified in the plaintiff’s complaint. 13. Copies of any documents provided to drivers as part of their training or orientation. 14. If you are not supplying any statement, report, medical record or other item requested herein, identify the item; indicate who has possession of the item; specify their address and state the reason why the items are not being provided. 15. Provide copies of all documents you intend to use at trial, including cross-examination and for impeachment purposes. 16. Was any type of surveillance taken of the plaintiff and, if so, state the name, address and occupation of the person performing such surveillance, the dates of this surveillance, and produce copies of any and all surveillance materials along with logs and any other materials relating to the surveillance. 17. Provide all videos and/or images and/or photographs and/or any depiction of the plaintiff. 18. Provide all videos and/or images and/or photographs and/or any depiction of the accident scene and of the accident itself. 19. With respect to any expert of the defendant, provide: i) a complete statement of all opinions the witness will express and the basis and reasons for them: ii) the date or other information considered by the witness in forming them; iii) any exhibits that will be used to summarize or support them; 6 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 7 of 8 Trans ID: LCV20231633631 iv) the witness’s qualifications, including a list of all publications authored in the previous 10 years; v) a list of all other cases in which, during the previous four years, the witness testified as an expert at trial or by deposition; vi) a statement of the compensation to be paid for the study and testimony in this case. REQUEST FOR ADMISSIONS Pursuant to Rule 4:22-1, et seq., plaintiff hereby demands that all defendants provide the following documents: 1. The incident that forms the basis of this action occurred on the date and at the place referenced in the complaint. 2. You owned the vehicle attributed to you in the complaint at the time of the accident described in the complaint. 3. You operated the vehicle attributed to you in the complaint at the time of the accident described in the complaint. 4. Your vehicle was involved in the accident described in the complaint. 5. You were operating the vehicle referred to in statement number 3 above with the permission of the owner. 6. You gave permission to operate the vehicle referred to in statement number 4 above to the person operating it at the time of the subject accident. 7. The statements attributed to you in the crash description of the police report were made by you. 8. The verbal threshold or lawsuit limitation does not apply since plaintiff’s and/or defendants’ vehicles were commercial vehicles. DEMAND FOR DISCOVERY OF INSURANCE COVERAGE Pursuant to R. 4:10-2 (b) demand is hereby made that you disclose to the undersigned whether there are any insurance agreements or policies under which any person or firm carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse for payments made to satisfy the judgment. If the answer is "yes" attach a copy 7 MID-L-002942-23 05/24/2023 5:12:27 PM Pg 8 of 8 Trans ID: LCV20231633631 of each or in the alternative state, under oath or certification (a) number (b) name and address of insurer or issuer (c) inception and expiration dates (d) names and addresses of all persons insured thereunder (e) personal injury limits (f) property damage limits (g) medical payment limits (h) name and address of person who has custody and possession thereof (i) where and when each policy or agreement can be inspected and copied., (j) excess coverage, (k) concurrent coverage, (l) umbrella policies. GINARTE GONZALEZ WINOGRAD, L.L.P. Attorneys for Plaintiff /s/ Patrick F. Kelly BY:________________________________ PATRICK F. KELLY, ESQ. DATED: May 24, 2023 8 MID-L-002942-23 05/24/2023 MID-L-002942-23 05/24/20235:12:27 5:12:27PM PM Pg 1 of 2 Trans TransID: ID:LCV20231633631 LCV20231633631 Civil Case Information Statement Case Details: MIDDLESEX | Civil Part Docket# L-002942-23 Case Caption: MIRANDA DEPINEDA JULIA VS JUAREZ- Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- MARTINEZ ISMAEL VERBAL THRESHOLD) Case Initiation Date: 05/24/2023 Document Type: Complaint with Jury Demand Attorney Name: PATRICK KELLY Jury Demand: YES - 6 JURORS Firm Name: GINARTE GALLARDO GONZALEZ Is this a professional malpractice case? NO WINOGRAD, LLP Related cases pending: NO Address: 400 MARKET ST If yes, list docket numbers: NEWARK NJ 07105 Do you anticipate adding any parties (arising out of same Phone: 9738548400 transaction or occurrence)? NO Name of Party: PLAINTIFF : Miranda DePineda, Julia Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): None Are sexual abuse claims alleged by: Julia Miranda DePineda? 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) 05/24/2023 /s/ PATRICK KELLY Dated Signed MID-L-002942-23 05/24/2023 MID-L-002942-23 05/24/20235:12:27 5:12:27PM PM Pg 2 of 2 Trans TransID: ID:LCV20231633631 LCV20231633631