Preview
CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 1 of 5 Trans ID: LCV20231574926
Stacy P. Maza, Attorney ID# 045891992 Insurer of Defendant(s):
Jan Meyer, Attorney ID# 020391994 None known.
Law Offices of Jan Meyer & Associates, P.C.
1029 Teaneck Road
Second Floor
Teaneck, New Jersey 07666
(201) 862-9500
Attorneys for Plaintiffs
Our File Number: 20-4295923-1
SUPERIOR COURT OF NEW JERSEY
Drive New Jersey Insurance Company LAW DIVISION: CAPE MAY COUNTY
and Drive New Jersey Insurance
Company as subrogee of Dorothy M. Docket No.:
Long,
Civil Action
Plaintiffs,
COMPLAINT
-against-
Laquisha M. Billings,
Defendant.
Plaintiffs, Drive New Jersey Insurance Company and Drive New Jersey Insurance
Company as subrogee of Dorothy M. Long, say:
THE PARTIES
1. Plaintiff Drive New Jersey Insurance Company [hereinafter “Plaintiff”] is
located at 5920 Landerbrook Drive, Mayfield Heights, Ohio 44124 and does business in
Cape May County.
2. Dorothy M. Long [hereinafter “Plaintiff’s insured”]resides in Danville, PA
17821-8500.
3. Hereinafter, Plaintiffs, Drive New Jersey Insurance Company and Drive New
Jersey Insurance Company as subrogee of Dorothy M. Long, are referred to individually
CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 2 of 5 Trans ID: LCV20231574926
and/or collectively as "Plaintiffs."
4. Defendant Laquisha M. Billings resides at 1001 Madison Street, Chester, PA
19013.
FACTS RELEVANT TO ALL COUNTS
5. Plaintiff is in the business of automobile insurance.
6. Plaintiff’s insured is the insured under a certain policy issued by Plaintiff.
7. At all times relevant, Plaintiff’s insured owned a gold 2002 Lexus RX 300
[hereinafter “Plaintiff's insured's vehicle"].
8. On or about August 2, 2020, Plaintiff's Insured was operating the
aforementioned vehicle at Wildwood, New Jersey while traveling north on Pacific Ave.
9. At the same aforementioned time and place, Defendant Laquisha M. Billings
was operating a beige 2004 Chevrolet Impala [hereinafter "Defendant’s vehicle"] while
traveling west on Spencer Ave.
10. Upon information and belief, at all times relevant, Defendant’s vehicle was
owned, rented, and/or leased by Laquisha M. Billings.
11. At the same aforementioned time and place, Defendant Laquisha M. Billings
operated said vehicle in such an, including, but not limited to, careless and/or negligent
manner, so as to drive with inattention, failed to obey a traffic control device, and cause a
collision with the Plaintiff’s insured's vehicle. Defendant also was unlicensed at the time of
the accident.
12. In addition, or in the alternative, upon information and belief, Defendant was
negligent in maintaining said vehicle and/or in causing said vehicle to be operated while
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it was not in proper working order.
13. As a result of Defendant’s actions or omissions, Plaintiff’s insured sustained
property damage.
14. As a result of Defendant’s actions or omissions, Plaintiff paid claims as
follows:
Property damage $5,301.83
Deductible $500.00
Less Salvage ($516.15)
TOTAL $5,285.68
15. In addition, or in the alternative to the above stated proximate cause(s) of
Plaintiffs’ injuries, Defendant had a duty to insure Defendant’s vehicle and/or not to operate
an uninsured vehicle.
16. Upon information and belief, Defendant negligently and/or recklessly caused
said vehicle's operation while said vehicle was not insured as per relevant law.
17. Had Defendant properly insured Defendant’s vehicle as per relevant law,
Plaintiffs would have been able to recover damages from said insurance policy.
FIRST COUNT
(Negligence)
18. Plaintiffs repeat each prior paragraph of the Complaint with the same force
and effect as if set forth fully herein.
19. Defendant owed a duty of reasonable care to Plaintiff’s insured.
20. Defendant breached said duty.
21. As a result of Defendant’s actions or omissions, Plaintiff's insured(s)
sustained $5,285.68 in damages.
22. As a result of Defendant’s actions or omissions, Plaintiff paid claims in the
CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 4 of 5 Trans ID: LCV20231574926
amount of $5,285.68.
WHEREFORE, Plaintiffs demand judgment against Defendant as follows:
A. $5,285.68 plus future amounts if any;
B. Compelling arbitration or other appropriate dispute resolution for any matters
required to be thus resolved pursuant to relevant statute, regulation and/or
contractual agreements;
C. Costs of Suit;
D. Attorney Fees;
E. Indemnification;
F. Contribution;
G. Other relief as the Court may deem equitable and just.
Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C.
Stacy P. Maza, Esq.
Attorneys for Plaintiffs
1029 Teaneck Road, Second Floor
Teaneck, New Jersey 07666
DESIGNATION OF TRIAL COUNSEL
Pursuant to Rules of Court, notice is hereby given that Jan Meyer, Esq., is
designated as trial counsel in the above captioned matter.
CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 5 of 5 Trans ID: LCV20231574926
Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C.
Stacy P. Maza, Esq.
Attorneys for Plaintiffs
1029 Teaneck Road, Second Floor
Teaneck, New Jersey 07666
CERTIFICATION
Pursuant to Rule 4:5-1, it is hereby stated that the matter in controversy is not the
subject of any other civil action pending in any court or of a pending arbitration proceeding,
to the best of our knowledge or belief; also to the best of our belief, no other action or
arbitration proceeding is contemplated. Further, other than the parties set forth in this
pleading, we know of no other parties that should be joined in the above action. In addition,
we recognize the continuing obligation of each party to file and serve on all parties and the
court an amended certification if there is a change in the facts stated in this original
certification.
Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C.
Stacy P. Maza, Esq.
Attorneys for Plaintiffs
1029 Teaneck Road, Second Floor
Teaneck, New Jersey 07666
CPM-L-000194-23 05/18/2023
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Civil Case Information Statement
Case Details: CAPE MAY | Civil Part Docket# L-000194-23
Case Caption: DRIVE NEW JERSEY INS URANCE VS Case Type: AUTO NEGLIGENCE-PROPERTY DAMAGE
BILLINGS LAQUISHA Document Type: Complaint
Case Initiation Date: 05/18/2023 Jury Demand: NONE
Attorney Name: STACY F PLOTZ MAZA Is this a professional malpractice case? NO
Firm Name: JAN MEYER & ASSOCIATES, PC Related cases pending: NO
Address: 1029 TEANECK RD 2ND FL If yes, list docket numbers:
TEANECK NJ 07666 Do you anticipate adding any parties (arising out of same
Phone: 2018629500 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Drive New Jersey Insurance Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Drive New Jersey Insurance?
NO
Are sexual abuse claims alleged by: Drive New Jersey Insurance?
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)
05/18/2023 /s/ STACY F PLOTZ MAZA
Dated Signed
CPM-L-000194-23 05/18/2023
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TransID:
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LCV20231574926
Preview
CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 1 of 5 Trans ID: LCV20231574926 Stacy P. Maza, Attorney ID# 045891992 Insurer of Defendant(s): Jan Meyer, Attorney ID# 020391994 None known. Law Offices of Jan Meyer & Associates, P.C. 1029 Teaneck Road Second Floor Teaneck, New Jersey 07666 (201) 862-9500 Attorneys for Plaintiffs Our File Number: 20-4295923-1 SUPERIOR COURT OF NEW JERSEY Drive New Jersey Insurance Company LAW DIVISION: CAPE MAY COUNTY and Drive New Jersey Insurance Company as subrogee of Dorothy M. Docket No.: Long, Civil Action Plaintiffs, COMPLAINT -against- Laquisha M. Billings, Defendant. Plaintiffs, Drive New Jersey Insurance Company and Drive New Jersey Insurance Company as subrogee of Dorothy M. Long, say: THE PARTIES 1. Plaintiff Drive New Jersey Insurance Company [hereinafter “Plaintiff”] is located at 5920 Landerbrook Drive, Mayfield Heights, Ohio 44124 and does business in Cape May County. 2. Dorothy M. Long [hereinafter “Plaintiff’s insured”]resides in Danville, PA 17821-8500. 3. Hereinafter, Plaintiffs, Drive New Jersey Insurance Company and Drive New Jersey Insurance Company as subrogee of Dorothy M. Long, are referred to individually CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 2 of 5 Trans ID: LCV20231574926 and/or collectively as "Plaintiffs." 4. Defendant Laquisha M. Billings resides at 1001 Madison Street, Chester, PA 19013. FACTS RELEVANT TO ALL COUNTS 5. Plaintiff is in the business of automobile insurance. 6. Plaintiff’s insured is the insured under a certain policy issued by Plaintiff. 7. At all times relevant, Plaintiff’s insured owned a gold 2002 Lexus RX 300 [hereinafter “Plaintiff's insured's vehicle"]. 8. On or about August 2, 2020, Plaintiff's Insured was operating the aforementioned vehicle at Wildwood, New Jersey while traveling north on Pacific Ave. 9. At the same aforementioned time and place, Defendant Laquisha M. Billings was operating a beige 2004 Chevrolet Impala [hereinafter "Defendant’s vehicle"] while traveling west on Spencer Ave. 10. Upon information and belief, at all times relevant, Defendant’s vehicle was owned, rented, and/or leased by Laquisha M. Billings. 11. At the same aforementioned time and place, Defendant Laquisha M. Billings operated said vehicle in such an, including, but not limited to, careless and/or negligent manner, so as to drive with inattention, failed to obey a traffic control device, and cause a collision with the Plaintiff’s insured's vehicle. Defendant also was unlicensed at the time of the accident. 12. In addition, or in the alternative, upon information and belief, Defendant was negligent in maintaining said vehicle and/or in causing said vehicle to be operated while CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 3 of 5 Trans ID: LCV20231574926 it was not in proper working order. 13. As a result of Defendant’s actions or omissions, Plaintiff’s insured sustained property damage. 14. As a result of Defendant’s actions or omissions, Plaintiff paid claims as follows: Property damage $5,301.83 Deductible $500.00 Less Salvage ($516.15) TOTAL $5,285.68 15. In addition, or in the alternative to the above stated proximate cause(s) of Plaintiffs’ injuries, Defendant had a duty to insure Defendant’s vehicle and/or not to operate an uninsured vehicle. 16. Upon information and belief, Defendant negligently and/or recklessly caused said vehicle's operation while said vehicle was not insured as per relevant law. 17. Had Defendant properly insured Defendant’s vehicle as per relevant law, Plaintiffs would have been able to recover damages from said insurance policy. FIRST COUNT (Negligence) 18. Plaintiffs repeat each prior paragraph of the Complaint with the same force and effect as if set forth fully herein. 19. Defendant owed a duty of reasonable care to Plaintiff’s insured. 20. Defendant breached said duty. 21. As a result of Defendant’s actions or omissions, Plaintiff's insured(s) sustained $5,285.68 in damages. 22. As a result of Defendant’s actions or omissions, Plaintiff paid claims in the CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 4 of 5 Trans ID: LCV20231574926 amount of $5,285.68. WHEREFORE, Plaintiffs demand judgment against Defendant as follows: A. $5,285.68 plus future amounts if any; B. Compelling arbitration or other appropriate dispute resolution for any matters required to be thus resolved pursuant to relevant statute, regulation and/or contractual agreements; C. Costs of Suit; D. Attorney Fees; E. Indemnification; F. Contribution; G. Other relief as the Court may deem equitable and just. Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C. Stacy P. Maza, Esq. Attorneys for Plaintiffs 1029 Teaneck Road, Second Floor Teaneck, New Jersey 07666 DESIGNATION OF TRIAL COUNSEL Pursuant to Rules of Court, notice is hereby given that Jan Meyer, Esq., is designated as trial counsel in the above captioned matter. CPM-L-000194-23 05/18/2023 10:48:30 AM Pg 5 of 5 Trans ID: LCV20231574926 Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C. Stacy P. Maza, Esq. Attorneys for Plaintiffs 1029 Teaneck Road, Second Floor Teaneck, New Jersey 07666 CERTIFICATION Pursuant to Rule 4:5-1, it is hereby stated that the matter in controversy is not the subject of any other civil action pending in any court or of a pending arbitration proceeding, to the best of our knowledge or belief; also to the best of our belief, no other action or arbitration proceeding is contemplated. Further, other than the parties set forth in this pleading, we know of no other parties that should be joined in the above action. In addition, we recognize the continuing obligation of each party to file and serve on all parties and the court an amended certification if there is a change in the facts stated in this original certification. Dated: May 18, 2023 Law Offices of Jan Meyer and Associates, P.C. Stacy P. Maza, Esq. Attorneys for Plaintiffs 1029 Teaneck Road, Second Floor Teaneck, New Jersey 07666 CPM-L-000194-23 05/18/2023 CPM-L-000194-23 05/18/202310:48:30 10:48:30AM AM Pg 1 of 2 Trans TransID: ID:LCV20231574926 LCV20231574926 Civil Case Information Statement Case Details: CAPE MAY | Civil Part Docket# L-000194-23 Case Caption: DRIVE NEW JERSEY INS URANCE VS Case Type: AUTO NEGLIGENCE-PROPERTY DAMAGE BILLINGS LAQUISHA Document Type: Complaint Case Initiation Date: 05/18/2023 Jury Demand: NONE Attorney Name: STACY F PLOTZ MAZA Is this a professional malpractice case? NO Firm Name: JAN MEYER & ASSOCIATES, PC Related cases pending: NO Address: 1029 TEANECK RD 2ND FL If yes, list docket numbers: TEANECK NJ 07666 Do you anticipate adding any parties (arising out of same Phone: 2018629500 transaction or occurrence)? NO Name of Party: PLAINTIFF : Drive New Jersey Insurance Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): Unknown Are sexual abuse claims alleged by: Drive New Jersey Insurance? NO Are sexual abuse claims alleged by: Drive New Jersey Insurance? 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) 05/18/2023 /s/ STACY F PLOTZ MAZA Dated Signed CPM-L-000194-23 05/18/2023 CPM-L-000194-23 05/18/202310:48:30 10:48:30AM AM Pg 2 of 2 Trans TransID: ID:LCV20231574926 LCV20231574926