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CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 1 of 4 Trans ID: LCV20231430756
SUPERIOR COURT OF NEW JERSEY, LAW DIVISION
CAPE MAY COUNTY
ERNEST WILLIAMS, :
:
Plaintiff, : Civil Action
:
v. :
:
LINDA MARTIN and JOHN :
MARTIN and/or : DOCKET NO.:
JOHN DOE :
:
Defendants. : COMPLAINT and JURY DEMAND
The Plaintiff, ERNEST WILLIAMS, residing at 793 Lambs Road, Pitman, New Jersey,
08071, by way of Complaint against the above-named parties, says:
FIRST COUNT
1. On or about September 3, 2021, the Plaintiff, ERNEST WILLIAMS, was the
driver of a vehicle traveling west on Washington Street, at or near 1020 Washington Street, in
Cape May City, Cape May County, New Jersey, when the Defendant, LINDA MARTIN,
operating her motor vehicle, proceeded to back out of the driveway located at 1020 Washington
Street, causing her vehicle to strike the vehicle being operated by the Plaintiff, ERNEST
WILLIAMS, at the time
2. At the aforementioned time and place, the Defendant, LINDA MARTIN and/or
JOHN DOE, fictitious name representing a driver whose identity cannot be reasonably
ascertained at this time, was backing out of the driveway located at 1020 Washington Street in
Cape May City, Cape May County, New Jersey.
3. At said time and place, the Defendants, LINDA MARTIN and/or JOHN DOE,
operated her vehicle in such a careless and negligent fashion, resulted in her vehicle crashing into
CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 2 of 4 Trans ID: LCV20231430756
the vehicle being operated by Plaintiff, ERNEST WILLIAMS, as the Plaintiff drove his vehicle
west on Washington Street, Cape May City, Cape May County, New Jersey, causing personal
injury to the Plaintiff.
4. By reason of the aforesaid, the Plaintiff, ERNEST WILLIAMS, was severely and
permanently injured, suffered, still suffers and will, in the future, suffer great pain and anguish,
was confined for a period of time and will so be confined in the future, became, still is and will,
in the future, be incapacitated from continuing his usual course of conduct and/or employment,
was obliged to incur large expenses in the care and treatment of the aforesaid injuries and was
otherwise injured, damaged and restricted in his bodily movements.
WHEREFORE, the Plaintiff, ERNEST WILLIAMS, demands judgment against the
Defendants, LINDA WILLIAMS and/or JOHN DOE, jointly, severally and/or in the alternative
for such sums as will reasonably compensate the Plaintiff for his damages according to the laws
of New Jersey, plus costs of suit, and for whatever other relief the Court deems equitable and
just.
SECOND COUNT
The Plaintiff, ERNEST WILLIAMS, hereby repeats each and every allegation of the First
Count and makes same a part hereof as though set forth at length herein.
5. JOHN MARTIN, is an individual, or a business entity, who was the agency and/or
employer of the Defendants, YVONNE R. FRANCOIS and/or JOHN DOE.
6. At the aforesaid time, the Defendants, LINDA MARTIN and/or JOHN DOE, was
the agent, servant and/or employee of the Defendant, JOHN MARTIN and operated said vehicle
in the scope of that employment.
CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 3 of 4 Trans ID: LCV20231430756
7. The Defendant, JOHN MARTIN is responsible to the Plaintiff, ERNEST
WILLIAMS, for the acts of the Defendants, LINDA MARTIN and/or JOHN DOE, through the
Doctrine of Respondeat Superior.
WHEREFORE, the Plaintiff, ERNEST WILLIAMS, demands judgment against the
Defendants, LINDA MARTIN, JOHN MARTIN, and/or JOHN DOE, jointly, severally and/or in
the alternative for such sums as will reasonably compensate the Plaintiff for his damages
according to the laws of New Jersey, plus costs of suit, and for whatever other relief the Court
deems equitable and just.
DEMAND FOR JURY TRIAL
PLEASE TAKE NOTICE that the Plaintiff hereby demands a trial by jury as to all issues
contained herein.
FURIA AND TURNER, LLC
Dated: May 2, 2023 By: FURIA AND TURNER, LLC
JAMES M.P. TURNER, JR., ESQ.
Attorney ID: 31838
120 E. State Street
Media, PA 19063
215-985-4500
jturner@furiaandturner.com
Attorney for Plaintiff
CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 4 of 4 Trans ID: LCV20231430756
CERTIFICATION PURSUANT TO R. 4:5-1
This is to certify that, to the best of my knowledge, the matter in controversy is not the
subject of any other action pending in any court or of a pending arbitration proceeding, nor is any
other action or arbitration proceeding contemplated. Further, at this time, there are no known
other parties who should be joined in this action.
FURIA AND TURNER, LLC
Dated: May 2, 2023 By: JAMES M.P. TURNER, JR., ESQ.
Attorney ID: 31838
120 E. State Street
Media, PA 19063
215-985-4500
jturner@furiaandturner.com
Attorney for Plaintiff
CPM-L-000173-23 05/02/2023
CPM-L-000173-23 05/02/202311:42:50
11:42:50AM
AM Pg 1 of 1 Trans
TransID:
ID:LCV20231430756
LCV20231430756
Civil Case Information Statement
Case Details: CAPE MAY | Civil Part Docket# L-000173-23
Case Caption: WILLIAMS ERNEST VS MARTIN LINDA Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
Case Initiation Date: 05/02/2023 THRESHOLD)
Attorney Name: JAMES M P TURNER JR Document Type: Complaint with Jury Demand
Firm Name: FURIA AND TURNER, LLC Jury Demand: YES - 6 JURORS
Address: 120 E. STATE ST Is this a professional malpractice case? NO
MEDIA PA 19380 Related cases pending: NO
Phone: 2159854500 If yes, list docket numbers:
Name of Party: PLAINTIFF : Williams, Ernest Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? YES
(if known): None Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: Ernest Williams? 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)
05/02/2023 /s/ JAMES M P TURNER JR
Dated Signed
Preview
CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 1 of 4 Trans ID: LCV20231430756 SUPERIOR COURT OF NEW JERSEY, LAW DIVISION CAPE MAY COUNTY ERNEST WILLIAMS, : : Plaintiff, : Civil Action : v. : : LINDA MARTIN and JOHN : MARTIN and/or : DOCKET NO.: JOHN DOE : : Defendants. : COMPLAINT and JURY DEMAND The Plaintiff, ERNEST WILLIAMS, residing at 793 Lambs Road, Pitman, New Jersey, 08071, by way of Complaint against the above-named parties, says: FIRST COUNT 1. On or about September 3, 2021, the Plaintiff, ERNEST WILLIAMS, was the driver of a vehicle traveling west on Washington Street, at or near 1020 Washington Street, in Cape May City, Cape May County, New Jersey, when the Defendant, LINDA MARTIN, operating her motor vehicle, proceeded to back out of the driveway located at 1020 Washington Street, causing her vehicle to strike the vehicle being operated by the Plaintiff, ERNEST WILLIAMS, at the time 2. At the aforementioned time and place, the Defendant, LINDA MARTIN and/or JOHN DOE, fictitious name representing a driver whose identity cannot be reasonably ascertained at this time, was backing out of the driveway located at 1020 Washington Street in Cape May City, Cape May County, New Jersey. 3. At said time and place, the Defendants, LINDA MARTIN and/or JOHN DOE, operated her vehicle in such a careless and negligent fashion, resulted in her vehicle crashing into CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 2 of 4 Trans ID: LCV20231430756 the vehicle being operated by Plaintiff, ERNEST WILLIAMS, as the Plaintiff drove his vehicle west on Washington Street, Cape May City, Cape May County, New Jersey, causing personal injury to the Plaintiff. 4. By reason of the aforesaid, the Plaintiff, ERNEST WILLIAMS, was severely and permanently injured, suffered, still suffers and will, in the future, suffer great pain and anguish, was confined for a period of time and will so be confined in the future, became, still is and will, in the future, be incapacitated from continuing his usual course of conduct and/or employment, was obliged to incur large expenses in the care and treatment of the aforesaid injuries and was otherwise injured, damaged and restricted in his bodily movements. WHEREFORE, the Plaintiff, ERNEST WILLIAMS, demands judgment against the Defendants, LINDA WILLIAMS and/or JOHN DOE, jointly, severally and/or in the alternative for such sums as will reasonably compensate the Plaintiff for his damages according to the laws of New Jersey, plus costs of suit, and for whatever other relief the Court deems equitable and just. SECOND COUNT The Plaintiff, ERNEST WILLIAMS, hereby repeats each and every allegation of the First Count and makes same a part hereof as though set forth at length herein. 5. JOHN MARTIN, is an individual, or a business entity, who was the agency and/or employer of the Defendants, YVONNE R. FRANCOIS and/or JOHN DOE. 6. At the aforesaid time, the Defendants, LINDA MARTIN and/or JOHN DOE, was the agent, servant and/or employee of the Defendant, JOHN MARTIN and operated said vehicle in the scope of that employment. CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 3 of 4 Trans ID: LCV20231430756 7. The Defendant, JOHN MARTIN is responsible to the Plaintiff, ERNEST WILLIAMS, for the acts of the Defendants, LINDA MARTIN and/or JOHN DOE, through the Doctrine of Respondeat Superior. WHEREFORE, the Plaintiff, ERNEST WILLIAMS, demands judgment against the Defendants, LINDA MARTIN, JOHN MARTIN, and/or JOHN DOE, jointly, severally and/or in the alternative for such sums as will reasonably compensate the Plaintiff for his damages according to the laws of New Jersey, plus costs of suit, and for whatever other relief the Court deems equitable and just. DEMAND FOR JURY TRIAL PLEASE TAKE NOTICE that the Plaintiff hereby demands a trial by jury as to all issues contained herein. FURIA AND TURNER, LLC Dated: May 2, 2023 By: FURIA AND TURNER, LLC JAMES M.P. TURNER, JR., ESQ. Attorney ID: 31838 120 E. State Street Media, PA 19063 215-985-4500 jturner@furiaandturner.com Attorney for Plaintiff CPM-L-000173-23 05/02/2023 11:42:50 AM Pg 4 of 4 Trans ID: LCV20231430756 CERTIFICATION PURSUANT TO R. 4:5-1 This is to certify that, to the best of my knowledge, the matter in controversy is not the subject of any other action pending in any court or of a pending arbitration proceeding, nor is any other action or arbitration proceeding contemplated. Further, at this time, there are no known other parties who should be joined in this action. FURIA AND TURNER, LLC Dated: May 2, 2023 By: JAMES M.P. TURNER, JR., ESQ. Attorney ID: 31838 120 E. State Street Media, PA 19063 215-985-4500 jturner@furiaandturner.com Attorney for Plaintiff CPM-L-000173-23 05/02/2023 CPM-L-000173-23 05/02/202311:42:50 11:42:50AM AM Pg 1 of 1 Trans TransID: ID:LCV20231430756 LCV20231430756 Civil Case Information Statement Case Details: CAPE MAY | Civil Part Docket# L-000173-23 Case Caption: WILLIAMS ERNEST VS MARTIN LINDA Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL Case Initiation Date: 05/02/2023 THRESHOLD) Attorney Name: JAMES M P TURNER JR Document Type: Complaint with Jury Demand Firm Name: FURIA AND TURNER, LLC Jury Demand: YES - 6 JURORS Address: 120 E. STATE ST Is this a professional malpractice case? NO MEDIA PA 19380 Related cases pending: NO Phone: 2159854500 If yes, list docket numbers: Name of Party: PLAINTIFF : Williams, Ernest Do you anticipate adding any parties (arising out of same Name of Defendant’s Primary Insurance Company transaction or occurrence)? YES (if known): None Does this case involve claims related to COVID-19? NO Are sexual abuse claims alleged by: Ernest Williams? 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) 05/02/2023 /s/ JAMES M P TURNER JR Dated Signed