Preview
MID-L-005311-22 07/14/2023 8:39:07 AM Pg 1 of 2 Trans ID: LCV20232080289
SALTZ MONGELUZZI BENDESKY
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
MGidaro/JWeiss/DGeorges@smbb.com
Identification No.: 01511-1992/02326-2010/43086-2023
Sagemore Corporate Center
8000 Sagemore Drive, Suite 8303
Marlton, NJ 08053
(856) 751-8383 Attorneys for Plaintiffs
WILFRED THOMAS and : SUPERIOR COURT OF NEW JERSEY
RHONDA THOMAS, h/w, : MIDDLESEX COUNTY
Plaintiffs, : LAW DIVISION
:
vs. : DOCKET NO. L-005311-22
:
HMH HOSPITALS CORPORATION D/B/A :
RARITAN BAY MEDICAL CENTER, :
HACKENSACK MERIDIAN HEALTH, INC., :
HACKENSACK UNIVERSITY MEDICAL :
CENTER, ABRAM WAHBA, M.D., : NOTICE OF PLAINTIFFS’ MOTION
MOHAMMED A. ISLAM, M.D., : TO COMPEL DEFENDANT, RENU
HACKENSACK MERIDIAN MEDICAL : MITTAL, RN TO ANSWER
GROUP, GARY B. BREITBART, M.D., : UNIFORM INTERROGATORIES,
GARDEN STATE SURGICAL ASSOCIATES, : FORM C AND FORM C(3),
P.A., SAMANTHA TUPAYACHI, RN, : PLAINTIFFS’ NOTICE TO PRODUCE
MAUREEN ESCOBOZA, RN, SEENA : SET I AND PLAINTIFFS’
GEORGE, RN, AND RENU MITTAL, RN, : SUPPLEMENTAL
Defendants : INTERROGATORIES SET I
PLEASE TAKE NOTICE that on Friday, August 4, 2023, at 9:00 a.m., or soon thereafter
as counsel may be heard, the undersigned counsel for plaintiffs in the above-captioned matter will
move before the Superior Court of New Jersey, Middlesex County, 56 Paterson Street, New
Brunswick, New Jersey 08903, for an Order compelling Defendant, Renu Mittal, RN, to respond
to Uniform Interrogatories, Form C and Form C(3), Plaintiffs’ Notice to Produce Set I, and
Plaintiffs’ Supplemental Interrogatories Set I.
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Movant will rely upon the enclosed certification of counsel in support of the Motion and
submits this Motion to the Court pursuant to Rule 1:6-2, thereby waiving oral argument unless
timely opposition is filed.
SALTZ MONGELUZZI BENDESKY
Dated: July 14, 2023 By: /s/ Jason S. Weiss
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
Attorneys for Plaintiffs
I hereby certify that the original Motion and proposed form of Order were filed with the
Middlesex County Clerk within the time prescribed by R. 1:6-3.
SALTZ MONGELUZZI BENDESKY
Dated: July 14, 2023 By: /s/ Jason S. Weiss
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
Attorneys for Plaintiffs
I hereby certify that this case is not currently scheduled for trial.
SALTZ MONGELUZZI BENDESKY
Dated: July 14, 2023 By: /s/ Jason S. Weiss
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
Attorneys for Plaintiffs
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WILFRED THOMAS and : SUPERIOR COURT OF NEW JERSEY
RHONDA THOMAS, h/w, : MIDDLESEX COUNTY
Plaintiffs, : LAW DIVISION
:
vs. : DOCKET NO. L-005311-22
:
HMH HOSPITALS CORPORATION D/B/A :
RARITAN BAY MEDICAL CENTER, :
HACKENSACK MERIDIAN HEALTH, INC., :
HACKENSACK UNIVERSITY MEDICAL :
CENTER, ABRAM WAHBA, M.D., :
MOHAMMED A. ISLAM, M.D., :
HACKENSACK MERIDIAN MEDICAL :
GROUP, GARY B. BREITBART, M.D., :
GARDEN STATE SURGICAL ASSOCIATES, :
P.A., SAMANTHA TUPAYACHI, RN, :
MAUREEN ESCOBOZA, RN, SEENA : ORDER
GEORGE, RN, AND RENU MITTAL, RN, :
Defendants :
This matter having come before the Court upon application of Saltz Mongeluzzi Bendesky,
attorneys for Plaintiffs, for an Order Compelling Defendant, Renu Mittal, RN, to provide responses
to Uniform Interrogatories, Form C and Form C(3), Plaintiffs’ Notice to Produce Set I, and
Plaintiffs’ Supplemental Interrogatories Set I, and the Court having read the moving papers, and
any papers filed in opposition thereto, and for good cause shown, it is hereby ORDERED and
DECREED that said Motion is GRANTED.
Defendant, Renu Mittal, RN, shall provide responses to Uniform Interrogatories, Form C
and Form C(3), Plaintiffs’ Notice to Produce Set I, and Plaintiffs’ Supplemental Interrogatories
Set I within ten (10) days from the date of this Order, or suffer sanctions as the Court may
hereinafter order.
J.S.C.
OPPOSED
UNOPPOSED
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SALTZ MONGELUZZI BENDESKY
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
MGidaro/JWeiss/DGeorges@smbb.com
Identification No.: 01511-1992/02326-2010/43086-2023
Sagemore Corporate Center
8000 Sagemore Drive, Suite 8303
Marlton, NJ 08053
(856) 751-8383 Attorneys for Plaintiffs
WILFRED THOMAS and : SUPERIOR COURT OF NEW JERSEY
RHONDA THOMAS, h/w, : MIDDLESEX COUNTY
Plaintiffs, : LAW DIVISION
:
vs. : DOCKET NO. L-005311-22
:
HMH HOSPITALS CORPORATION D/B/A :
RARITAN BAY MEDICAL CENTER, :
HACKENSACK MERIDIAN HEALTH, INC., :
HACKENSACK UNIVERSITY MEDICAL : ATTORNEY CERTIFICATION IN
CENTER, ABRAM WAHBA, M.D., : SUPPORT OF PLAINTIFFS’ MOTION
MOHAMMED A. ISLAM, M.D., : TO COMPEL DEFENDANT, RENU
HACKENSACK MERIDIAN MEDICAL : MITTAL, RN TO ANSWER
GROUP, GARY B. BREITBART, M.D., : UNIFORM INTERROGATORIES,
GARDEN STATE SURGICAL ASSOCIATES, : FORM C AND FORM C(3),
P.A., SAMANTHA TUPAYACHI, RN, : PLAINTIFFS’ NOTICE TO PRODUCE
MAUREEN ESCOBOZA, RN, SEENA : SET I, AND PLAINTIFFS’
GEORGE, RN, AND RENU MITTAL, RN, : SUPPLEMENTAL
Defendants : INTERROGATORIES SET I
I, Jason S. Weiss, Esquire, hereby certify as follows:
1. I am an attorney at law in the State of New Jersey and am associated with the law
firm of Saltz Mongeluzzi Bendesky. I am counsel for Plaintiffs in this matter. I am making this
certification in support of Plaintiffs’ Motion to Compel Responses of Defendant, Renu Mittal, RN,
to Uniform Interrogatories, Form C and Form C(3), Plaintiffs’ Notice to Produce Set I, and
Plaintiffs’ Supplemental Interrogatories Set I. I am making this certification upon personal
knowledge unless otherwise indica
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2. This is a medical malpractice action filed on October 25, 2022 stemming from the
alleged medical negligence of the above captioned Defendants.
3. Plaintiffs’ counsel served their request to answer Uniform Interrogatories, Form C
and Form C(3) with their Complaint on October 31, 2022 on Defendant, Renu Mittal, RN.
4. On March 9, 2023, Plaintiffs’ counsel served Plaintiffs’ Notice to Produce Set I and
Plaintiffs’ Supplemental Interrogatories Set I Directed to Defendant, Renu Mittal, RN, via
electronic mail to his counsel, Dughi Hewit & Domalewski, and requested that responses be
provided within the time limits set forth in the New Jersey Rules of Civil Procedure. (A true and
correct copy of the enclosure letter, Plaintiffs’ Notice to Produce Set I Directed to Defendant, Renu
Mittal, RN and Plaintiffs’ Supplemental Interrogatories Set I Directed to Defendant, Renu Mittal,
RN dated March 9, 2023 is attached collectively hereto and marked as Exhibit “A”.)
5. On June 14, 2023, Plaintiffs’ counsel sent a reminder letter to counsel for
Defendant, Renu Mittal, RN, via electronic mail requesting responses to Uniform Interrogatories,
Form C and Form C(3), Plaintiffs’ Notice to Produce Set I, and Plaintiffs’ Supplemental
Interrogatories Set I within ten (10) days from the date of the letter. (A true and correct copy of
the June 14, 2023 letter is attached hereto and marked as Exhibit “B”.)
6. To date, Defendant, Renu Mittal, RN, has not provided responses to Uniform
Interrogatories, Form C and Form C(3) that were served on October 31, 2022 and responses to
Plaintiffs’ Notice to Produce Set I and Plaintiffs’ Supplemental Interrogatories Set I that were
served on March 9, 2023.
7. No requests for extensions have been received or granted.
8. Defendant, Renu Mittal, RN, has not objected to the discovery requests.
9. The discovery deadline in this matter is February 14, 2024.
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10. Pursuant to R. 4:10-2(a):
“Parties may obtain discovery regarding any matter, not privileged, which
is relevant to the subject matter involved in the pending action, whether
it relates to the claim or defense of the parties seeking discovery or
to the claim or defense of any other party, including the existence,
description, nature, custody, condition, and location of any books,
documents, or other tangible things and the identity and location
of persons having knowledge of any discoverable matter. It is not
grounds for objection that the information sought will be inadmissible
at the trial if the information sought appears reasonably calculated to
lead to the discovery of admissible evidence; nor is it grounds for
objection that the examining party has knowledge of the matter
to which discovery is sought.”
11. Given the provisions of the rules, Defendant, Renu Mittal, RN, should be compelled
to provide responses to Uniform Interrogatories, Form C and Form C(3), Plaintiffs’ Notice to
Produce Set I, and Plaintiffs’ Supplemental Interrogatories Set I without further delay.
12. For all of the aforementioned reasons, Plaintiffs now request this Honorable Court
to enter an Order compelling Defendant, Renu Mittal, RN, to provide complete responses to
Uniform Interrogatories, Form C and Form C(3), Plaintiffs’ Notice to Produce Set I, and Plaintiffs’
Supplemental Interrogatories Set I.
13. A proposed form of Order accompanies this certification.
14. We certify that the foregoing statements made by us are true. We are aware that if
any of the foregoing statements made by us are willfully false, we are subject to punishment.
Respectfully submitted,
SALTZ MONGELUZZI BENDESKY
Dated: July 14, 2023 By: /s/ Jason S. Weiss
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
Attorneys for Plaintiffs
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SALTZ MONGELUZZI BENDESKY
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE
DENISE H. GEORGES, ESQUIRE
MGidaro/JWeiss/DGeorges@smbb.com
Identification No.: 01511-1992/02326-2010/43086-2023
Sagemore Corporate Center
8000 Sagemore Drive, Suite 8303
Marlton, NJ 08053
(856) 751-8383 Attorneys for Plaintiffs
WILFRED THOMAS and : SUPERIOR COURT OF NEW JERSEY
RHONDA THOMAS, h/w, : MIDDLESEX COUNTY
Plaintiffs, : LAW DIVISION
:
vs. : DOCKET NO. L-005311-22
:
HMH HOSPITALS CORPORATION D/B/A :
RARITAN BAY MEDICAL CENTER, :
HACKENSACK MERIDIAN HEALTH, INC., :
HACKENSACK UNIVERSITY MEDICAL :
CENTER, ABRAM WAHBA, M.D., :
MOHAMMED A. ISLAM, M.D., :
HACKENSACK MERIDIAN MEDICAL :
GROUP, GARY B. BREITBART, M.D., :
GARDEN STATE SURGICAL ASSOCIATES, :
P.A., SAMANTHA TUPAYACHI, RN, :
MAUREEN ESCOBOZA, RN, SEENA : PROOF OF MAILING
GEORGE, RN, AND RENU MITTAL, RN, :
Defendants :
I, Jason S. Weiss, Esquire, of full age, hereby certify that:
I am an attorney at law in the State of New Jersey and represent Plaintiffs, Wilfred
Thomas and Rhonda Thomas, in this matter. I hereby certify that on July 14, 2023, the within
Motion to Compel Defendant, Renu Mittal, RN, to Respond to Uniform Interrogatories, Form C
and Form C(3), Plaintiffs’ Notice to Produce Set I, and Plaintiffs’ Supplemental Interrogatories
Set I was served via electronic filing to the following counsel:
Anthony Cocca, Esquire Joseph A. DiCroce, Esquire
Cocca & Cutinello, LLP Steven B. Farman, Esquire
The Point at Morristown Law Offices of Joseph A. DiCroce, LLC
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36 Cattano Avenue, Suite 600 Valley Park Professional Center
Morristown, New Jersey 07960 2517 Highway 35
Attorneys for Defendants, Raritan Bay Medical Building N – Suite 201
Center, a division of HMH Hospitals Corporation, Manasquan, New Jersey 08736
improperly pled as “HMH Hospitals Corporation Attorneys for Defendant, Abram Wahba,
d/b/a Raritan Bay Medical Center”, Hackensack M.D.
Meridian Health, Inc., Hackensack Meridian
Health Medical Group, Hackensack University
Medical Center, a division of HMH Hospitals
Corporation, improperly pled as “Hackensack
University Medical Center”, Mohammed Islam,
M.D., Seena George, R.N., Maureen Escoboza,
R.N., and Samantha Tupayachi, R.N.
Gregory J. Giordano, Esquire Herbert Kruttschnitt, III, Esquire
Lenox Socey Formidoni Giordano Cyndee L. Allert, Esquire
Lang Carrigg & Casey LLC Dughi Hewit & Domalewski
136 Franklin Corner Road, Unit B-2 340 North Avenue
Lawrenceville, New Jersey 08648 Cranford, New Jersey 07106
Attorneys for Defendants, Gary B. Breitbart, Attorneys for Defendant, Renu Mittal, RN
M.D. and Garden State Surgical Associates, P.A.
Respectfully submitted,
SALTZ MONGELUZZI BENDESKY
By: /s/ Jason S. Weiss
JASON S. WEISS, ESQUIRE
Attorneys for Plaintiffs
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EXHIBIT “A”
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SALTZ
Zo MONGELUZZI
BENDESKY
TRIAL LAWYERS
DELAWARE COUNTY OFFICE ONE LIBERTY PLACE, 52ND FLOOR NEW JERSEY OFFICE
20 WEST THIRD STREET 1650 MARKET STREET 8000 SAGEMORE DRIVE
P.O. BOX 1670 PHILADELPHIA, PA 19103 SUITE 8303
MEDIA, PA 19063 VOICE 215.496.8282 MARLTON, NJ 08053
VOICE 610.627.9777 FAX 215.496.0999 VOICE 856.751.8383
FAX 610.627.9787 FAX 856.751.0868
MONTGOMERY COUNTY OFFICE
120 GIBRALTAR RD
JASON S. WEISS, ESQUIRE SUITE 218
DIRECT DIAL: (215) 575-2992
JWEISS@SMBB.COM
HORSHAM, PA 19044
VOICE 215.496.8282
FAX 215.754.4443
March 9, 2023
Via Electronic Mail
Herbert Kruttschnitt, III, Esquire
Dughi Hewit & Domalewski
340 North Avenue
Cranford, New Jersey 07106
Re: Thomas v. HMH Hospitals Corporation, et al.
Superior Court of New Jersey, Docket No. MID-L-5311-22
Counsel:
Enclosed is Plaintiffs’ Notice to Produce Set I and Plaintiffs’ Supplemental
Interrogatories Set I Directed to Defendant, Renu Mittal, RN.
Additionally, as you may recall, Plaintiffs served Defendant, Renu Mittal, RN, on
October 31, 2022 in their Complaint filed on October 25, 2022, with a demand for answers to
Uniform Interrogatories, Form C and Form C(3).
Kindly provide responses in accordance with the New Jersey Rules of Civil Procedure.
Thank you for your attention to this matter.
Very truly yours,
SALTZ MONGELUZZI BENDESKY P.C.
/s/ Jason S. Weiss
JASON S. WEISS, ESQUIRE
JSW:dmr
Enclosures
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Page 2
March 9, 2023
cc: Anthony Cocca, Esquire (via email w/ enclosures)
Joseph A. DiCroce, Esquire (via email w/enclosures)
Gregory Giordano, Esquire (via email w/enclosures)
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SALTZ MONGELUZZI BENDESKY P.C.
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE ATTORNEYS FOR PLAINTIFFS
MGidaro/JWeiss@smbb.com
Identification No. 01511-1992/02326-2010
Sagemore Corporate Center, Suite 8303
8000 Sagemore Drive
Marlton, New Jersey 08053
(856) 751-8383
WILFRED THOMAS and : SUPERIOR COURT OF
RHONDA THOMAS, h/w, : NEW JERSEY
Plaintiffs : MIDDLESEX COUNTY
: LAW DIVISION
v. :
: DOCKET NO. L-005311-22
HMH HOSPITALS CORPORATION :
D/B/A RARITAN BAY MEDICAL :
CENTER, HACKENSACK MERIDIAN :
HEALTH, INC., HACKENSACK :
UNIVERSITY MEDICAL CENTER, :
ABRAM WAHBA, M.D., MOHAMMED :
A. ISLAM, M.D., HACKENSACK :
MERIDIAN MEDICAL GROUP, GARY :
B. BREITBART, M.D., GARDEN STATE: PLAINTIFFS’ NOTICE TO PRODUCE
SURGICAL ASSOCIATES P.A., : DIRECTED TO DEFENDANT RENU
SAMANTHA TUPAYACHI, RN, : MITTAL RN SET I
MAUREEN ESCOBOZA, RN, SEENA :
GEORGE, RN, and RENU MITTAL, RN,:
Defendants :
Plaintiffs, Wilfred Thomas and Rhonda Thomas, h/w, by and through their attorneys
hereby request that Defendant, Renu Mittal RN, produce the below-listed documents and
tangible things within thirty-five (35) days pursuant to New Jersey Court Rules.
DEFINITIONS AND INSTRUCTIONS
Pursuant to the New Jersey Court Rules, you are hereby requested to produce the below-
listed documents, and/or times for purposes of discovery. This material will be examined and/or
photocopied; photograph negatives will be processed, and photographs reproduced. Said
documents and tangible things are to be produced at the office of the undersigned within thirty-
five (35) days of the date of service hereof and supplemented thereafter in accordance with the
New Jersey Court Rules.
These requests are not directed merely to the person or party whose name appears above
but are meant to include that person or party’s agents, servants, insurers, employers, employees,
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investigators, attorneys, and others similarly situated to the main party or person, any and all of
whom may be referred to herein as “answering party”.
In addition, although the Notice seeks documents within thirty-five (35) days, the Notice
should also be deemed continuing in that if there are further materials which come under the
purview of any of these Notices which materials are obtained after the time of their production
presently, said material should also be furnished in accord with this Notice.
If any requested document is unavailable because it was lost or destroyed by Defendant,
Renu Mittal, RN, or their agents, or for any other reason, the defendant, Renu Mittal, RN, shall,
after fully identifying the document, state:
(a) When and where it was destroyed, or why it is otherwise unavailable;
(b) The name and address of each person who destroyed it;
(c) The name and address of each person who directed, approved, or knew of
its destruction; and,
(d) The name and address of each person who has knowledge of such
document.
If there is a claim of privilege with respect to any document requested, the defendant,
Renu Mittal, RN, shall:
(a) Identify in their answers each document for which a privilege is claimed;
(b) A description of the document;
(c) The date of the document;
(d) The names of the addressees and addressors;
(e) The identity and address of every person to whom a copy was given or
communicated;
(f) The general subject matter of the document;
(g) A statement of the facts constituting the basis for any claim of privilege;
and,
(h) The specific basis on which the privilege is claimed.
This Notice seeks certain documents and things identified as clearly as possible by
Plaintiffs. The description of records and things requested is not meant to indicate the precise
title of any specific document or thing and, therefore, your responses should not narrowly
construe this Notice as seeking a document or thing with a title which specifically bears the
general description by the Plaintiffs.
NOTICE TO PRODUCE DOCUMENTS AND THINGS SET I
Pursuant to New Jersey Court Rule 4:18-1, et seq, you are requested to produce the
following documents and tangible things:
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1. A copy of your complete investigative file, excluding reference to mental
impressions, conclusions or opinions representing the value or merit of a claim or defense, or
respecting strategy or tactics and further excluding privileged communications from counsel.
2. A copy of Defendant, Renu Mittal RN’s most recent Curriculum Vitae and/or
resumes.
3. A copy of all medical reports, records, notes, billing statements, other writings,
and/or hospital records that Defendant, Renu Mittal, RN, have in their possession, custody,
and/or control regarding treatment rendered to Plaintiff, Wilfred Thomas.
4. Any and all medical records, physician(s)’ reports and bills, hospital records or
abstracts of same, that were incorrect, made in error, altered, revised, and/or amended, which
relate in any way to the injuries allegedly sustained by Plaintiff, Wilfred Thomas, as well as the
treatment of any similar injuries prior or subsequent to the occurrence in question.
5. The originals of all films including MRI films, CT films, x-ray films, and any
other films, for studies performed on Plaintiff, Wilfred Thomas.
6. A copy of any and all policies of insurance, including excess and umbrella
policies of insurance, which are available to cover the claim of Plaintiffs.
7. All statements and non-privileged notes obtained by Defendant, Renu Mittal, RN,
which pertain to the care and treatment rendered to Plaintiff, Wilfred Thomas, which is the
subject matter of Plaintiffs’ Complaint.
8. Any and all experts’ reports, curricula vitae, and/or other writings prepared by
experts for Defendant, Renu Mittal, RN, that they expect to call at the time of trial.
9. Any and all documents upon which you have relied upon to support the defenses
contained in your answers to Plaintiffs’ Complaint.
10. All photographs, surveillance videos, videos, images, digital recordings, movies,
charts, and/or any other documentary evidence pertaining to the subject incident, occurrences, or
issues in this case including those taken of Plaintiff, Wilfred Thomas.
11. Please produce all documents in your possession, custody, or control which you
received from or sent to any expert witnesses, whom you either have or will designate to give
expert testimony during the course of the trial in this case.
12. Please produce a list of all books, articles, treatises, or publications which each
expert witness, whom you have or will designate, to give expert testimony during the course of
the trial in this case, plans to rely upon at the time of trial or time of his/her deposition.
13. Please produce any contracts of employment of Defendant, Renu Mittal, RN, to
which you were a party at the time of your professional contact with Plaintiff, Wilfred Thomas.
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15. Please produce any contracts of Defendant, Renu Mittal, RN, with Defendants,
HMH Hospitals Corporation d/b/a Raritan Bay Medical Center, Hackensack Meridian Health,
Inc., Hackensack University Medical Center, Hackensack Meridian Medical Group, and Garden
State Surgical Associates, P.A., for the provision of medical services regarding the medical care
provided to Plaintiff, Wilfred Thomas.
16. All documents or other demonstrative evidence which will be introduced or used
at trial.
17. Please produce all bylaws, policies, procedures, protocols, and regulations in
effect in November and December 2020 to emergently treat an acute limb ischemia.
SALTZ MONGELUZZI BENDESKY P.C.
By: /s/ Jason S. Weiss
Dated: March 9, 2023 JASON S. WEISS, ESQUIRE
Attorney for Plaintiffs
4
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SALTZ MONGELUZZI BENDESKY P.C.
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE ATTORNEYS FOR PLAINTIFFS
MGidaro/JWeiss@smbb.com
Identification No. 01511-1992/02326-2010
Sagemore Corporate Center, Suite 8303
8000 Sagemore Drive
Marlton, New Jersey 08053
(856) 751-8383
WILFRED THOMAS and : SUPERIOR COURT OF
RHONDA THOMAS, h/w, : NEW JERSEY
Plaintiffs : MIDDLESEX COUNTY
: LAW DIVISION
v. :
: DOCKET NO. L-005311-22
HMH HOSPITALS CORPORATION :
D/B/A RARITAN BAY MEDICAL :
CENTER, HACKENSACK MERIDIAN :
HEALTH, INC., HACKENSACK :
UNIVERSITY MEDICAL CENTER, :
ABRAM WAHBA, M.D., MOHAMMED :
A. ISLAM, M.D., HACKENSACK :
MERIDIAN MEDICAL GROUP, GARY :
B. BREITBART, M.D., GARDEN STATE: PLAINTIFFS’ SUPPLEMENTAL
SURGICAL ASSOCIATES P.A., : INTERROGATORIES DIRECTED TO
SAMANTHA TUPAYACHI, RN, : DEFENDANT RENU MITTAL RN
MAUREEN ESCOBOZA, RN, SEENA : SET I
GEORGE, RN, and RENU MITTAL, RN,:
Defendants :
Plaintiffs, Wilfred Thomas and Rhonda Thomas, h/w, by and through their attorneys
hereby propound the following Supplemental Interrogatories to be answered under oath by
Defendant, Renu Mittal RN, pursuant to the New Jersey Rules of Civil Procedure. These
Interrogatories are deemed continuing so as to require further answers from now until the time of
trial without further notice, if you learn of further information called for herein. These
Interrogatories are addressed to you as parties to this action and your answers shall be based
upon all information known to you, your attorneys, and your representatives.
DEFINITIONS
1. As used in these Interrogatories, the words and terms set forth below are defined as
follows:
“Describe” and “Specify” and/or “State” shall mean to set forth fully
and unambiguously, using technical terms and words of art, if
necessary, each and every fact relevant to the answer called for by
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the Interrogatory of which the answering party or the answering
party's agents, employees or representatives have knowledge.
“Identify” when referring to an individual means to state:
i. his or her name;
ii. title or job classification at the time of the events referred to in the
Interrogatory;
iii. present address, if known, and/or the last known address and
current address of last known employer.
“Identify” when referring to a document means to:
i. state the type of document (e.g., letter, journal, records,
memorandum); its date, title and identifying number, if any,
general subject matter and its present location;
ii. state each person who prepared it, each person for whom it was
prepared, the last known address of each person who presently has
custody of the original or copies thereof.
“Documents” shall mean the original or any identical copy of any
written, printed, typed, photographed or other graphic or recorded
matter or any kind or nature prepared or received, by or in the
possession, custody or control of the answering party, or the party’s
agent, servants, employees or other representatives.
“You” or “Your” shall mean to include the answering party and each
of the said party’s representatives, and where appropriate, the
directors, agents, officers, and employees and all other persons
acting for or on behalf of the answering party.
“Person” or “Persons” as used herein shall include, without
limitation, individuals, associations, partnerships and corporations.
SUPPLEMENTAL INTERROGATORIES SET I
1. Who was the employer of Defendant, Renu Mittal, R.N.?
2. What is the address of the employer of Defendant, Renu Mittal, R.N.?
3. Were there any bylaws, policies, procedures, protocols, and regulations in effect
in November and December 2020 to emergently treat an acute limb ischemia.
SALTZ MONGELUZZI BENDESKY P.C.
By: /s/ Jason S. Weiss
Dated: March 9, 2023 JASON S. WEISS, ESQUIRE
Attorney for Plaintiffs
2
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SALTZ MONGELUZZI BENDESKY P.C.
MARY T. GIDARO, ESQUIRE
JASON S. WEISS, ESQUIRE ATTORNEYS FOR PLAINTIFFS
MGidaro/JWeiss@smbb.com
Identification No. 01511-1992/02326-2010
Sagemore Corporate Center, Suite 8303
8000 Sagemore Drive
Marlton, New Jersey 08053
(856) 751-8383
WILFRED THOMAS and : SUPERIOR COURT OF
RHONDA THOMAS, h/w, : NEW JERSEY
Plaintiffs : MIDDLESEX COUNTY
: LAW DIVISION
v. :
: DOCKET NO. L-005311-22
HMH HOSPITALS CORPORATION :
D/B/A RARITAN BAY MEDICAL :
CENTER, HACKENSACK MERIDIAN :
HEALTH, INC., HACKENSACK :
UNIVERSITY MEDICAL CENTER, :
ABRAM WAHBA, M.D., MOHAMMED :
A. ISLAM, M.D., HACKENSACK :
MERIDIAN MEDICAL GROUP, GARY :
B. BREITBART, M.D., GARDEN STATE:
SURGICAL ASSOCIATES P.A., :
SAMANTHA TUPAYACHI, RN, :
MAUREEN ESCOBOZA, RN, SEENA :
GEORGE, RN, and RENU MITTAL, RN,: PROOF OF SERVICE
Defendants :
I, Jason S. Weiss, Esquire hereby certify that on March 9, 2023 I served Plaintiffs’ Notice
to Produce Set I and Plaintiffs’ Supplemental Interrogatories Set I on Defendant, Renu Mittal
RN, through their counsel listed below by electronic mail:
Anthony Cocca, Esquire Joseph A. DiCroce, Esquire
Cocca & Cutinello, LLP Law Offices of Joseph A. DiCroce, III
The Point at Morristown Valley Park Professional Center
36 Cattano Avenue, Suite 600 2517 Highway 35
Morristown, New Jersey 07960 Building N – Suite 201
Attorneys for Defendants, Raritan Bay Medical Manasquan, New Jersey 08736
Center, a division of HMH Hospitals Attorneys for Defendant Abram Wahba MD
Corporation, improperly pled as “HMH
Hospitals Corporation d/b/a Raritan Bay
Medical Center”, Hackensack Meridian Health,
MID-L-005311-22 07/14/2023 8:39:07 AM Pg 11 of 11 Trans ID: LCV20232080289
Inc., Hackensack Meridian Health Medical Group,
Hackensack University Medical Center, a division
of HMH Hospitals Corporation, improperly pled
as “Hackensack University Medical Center”,
Mohammed A. Islam, M.D., Seena George, R.N.,
Maureen Escoboza, R.N., and Samantha
Tupayachi, R.N.
Gregory J. Giordano, Esquire Herbert Kruttschnitt, III, Esquire
Lenox Socey Formidoni Giordano Dughi Hewit & Domalewski
Lang Carrigg & Casey LLC 340 North Avenue
136 Franklin Corner Road, Unit B-2 Cranford, New Jersey 07106
Lawrenceville, New Jersey 08648 Attorneys for Defendant, Renu Mittal, RN
Attorneys for Defendants, Gary B. Breitbart,
M.D. and Garden State Surgical
Associates, P.A.
SALTZ MONGELUZZI BENDESKY P.C.
By: /s/ Jason S. Weiss
JASON S. WEISS, ESQUIRE
2
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EXHIBIT “B”
MID-L-005311-22 07/14/2023 8:39:07 AM Pg 2 of 3 Trans ID: LCV20232080289
A SALTZ
MONGELUZZI
BENDESKY
TRIAL LAWYERS
DELAWARE COUNTY OFFICE ONE LIBERTY PLACE, 52ND FLOOR NEW JERSEY OFFICE
20 WEST THIRD STREET 1650 MARKET STREET 8000 SAGEMORE DRIVE
P.O. BOX 1670 PHILADELPHIA, PA 19103 SUITE 8303
MEDIA, PA 19063 VOICE 215.496.8282 MARLTON, NJ 08053
VOICE 610.627.9777 FAX 215.496.0999 VOICE 856.751.8383
FAX 610.627.9787 FAX 856.751.0868
MONTGOMERY COUNTY OFFICE
120 GIBRALTAR RD
JASON S. WEISS, ESQUIRE SUITE 218
DIRECT DIAL: (215) 575-2992
JWEISS@SMBB.COM
HORSHAM, PA 19044
VOICE 215.496.8282
FAX 215.754.4443
June 14, 2023
Via Electronic Mail
Herbert Kruttschnitt, III, Esquire
Dughi Hewit & Domalewski
340 North Avenue
Cranford, New Jersey 07106
Re: Thomas v. HMH Hospitals Corporation, et al.
Superior Court of New Jersey, Docket No. MID-L-5311-22
Counsel:
As you may recall on March 9, 2023, we served you with Plaintiffs’ Notice to Produce
Set I and Supplemental Interrogatories Set I Directed to Defendant, Renu Mittal RN. Plaintiffs
also requested answers to Uniform Interrogatories, Form C and Form C(3), at the time of filing
their Complaint on October 25, 2022.
To date, we have not received your clients’ responses. Kindly provide your clients’
responses within ten (10) days of the date of this letter in order to avoid motion practice.
Very truly yours,
SALTZ MONGELUZZI BENDESKY
/s/ Jason S. Weiss
JASON S. WEISS, ESQUIRE
JSW:dmr
cc: Anthony Cocca, Esquire (via email)
Steven B. Farman, Esquire (via email)
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Page 2
June 14, 2023
Gregory Giordano, Esquire (via email)