Preview
ESX-L-004552-22 02/09/2023 6:12:21PM Pglof2 Trans ID: LCV2023501728
NEWARK Mayor Ras J. Baraka
Department of Law A City We Can All Believe In
Kenyatta K. Stewart, Esq., Handel T. Destinvil, Esq.
Corporation Counsel Assistant Corporation Counsel
920 Broad Street, Room 316 destinvilh@ ci.newark.nj.u:
Newark, New J ersey 07102 Dir. (973) 733-3114
Office: (973)733-3880
Fax: (973) 733-5394
February 9, 2023
Via Electronic Filing
Chambers of the Hon. Annette Scoca, J .S.C.
Superior Court of New J ersey, Essex Vicinage, Law Division
Hall of Records, Chambers 304
465 Dr. Martin Luther King, J r. Boulevard
Newark, NJ 07102
Re: Ronald Ricketts v. Officer Samuel G. Gonzalez, et als.
DOCKET NO. ESX-L-4552-22
Your Honor:
The undersigned represents Defendant, City of Newark (“City”) in the above-
captioned matter.
OnJ anuary 30, 2023, Plaintiff, Ronald Ricketts (“Plaintiff”) filed a Motion to
Compel Production of Documents as to the City, pursuantto N.J .R. 4:23-5(c). (eCourts
Transaction ID: LCV2023400184). Specifically, Plaintiff sought production of
responses to Plaintiff's December 19, 2022 Notice to Produce, for which responses
were due on J anuary 23, 2023. See Rachmiel J an. 30, 2023 Cert 94 1-9.
The undersigned apologizes to the Court and fellow counsel for the delay in
production. However, the Court can take judicial notice, pursuantto N.J .R.E. 201(b)(4),
of the fact that today, at 5:31 PM EST, the City served responses to Plaintiff's Notice to
Produce. See Ex. A at 1-17, as attached to Destinvil Feb. 9, 2023 Cert. Accordingly,
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of2 Trans ID: LCV2023501728
Plaintiff's Motion to Compel Production of Documents can be denied as moot. See
Greenfield v. New J ersey Dep't of Corr., 382 N.J. Super. 254, 257-58 (App. Div.
2006)(“An issue is ‘moot’ when the decision sought in a matter, when rendered, can
have no practical effect on the existing controversy.”)(internal quotation and citation
omitted).
CONCLUSION
For the aforesaid reasons and authorities cited herein, the Court should deny
Plaintiff's J anuary 30, 2023 Motion to Compel Production of Documents as moot.
Respectfully submitted,
Kenyatta K. Stewart
Corporation Counsel
By: Bendel-FT—Destersed—€§
(St
Handel T. Destinvil, Esq.
Assistant Corporation Counsel
Enc.
cc: Joell. Rachmiel, Esq.
Via Electronic Filing: joelrachmiel@ aol.com
ESX-L-004552-22 02/09/2023 6:12:21PM Pglof2 Trans ID: LCV2023501728
KENYATTA K. STEWART, CORPORATION COUNSEL
CITY OF NEWARK — DEPARTMENT OF LAW
920 Broad Street, Room 316
Newark, NewJ ersey 07102
Attorney for Defendant, City of Newark
By: Handel T. Destinvil, Esq.
destinvilh@ ci.newark.nj.us
Assistant Corporation Counsel
NJ Bar ID#129102015
Telephone (973) 733-3114
Facsimile (973) 733-5394
RONALD RICKETTS, SUPERIOR COURT OF NEW J ERSEY
LAW DIVISION: ESSEX COUNTY
Plaintiff, DOCKET NO. ESX-L-4552-22
Vv. Civil Action
OFFICER SAMUEL C. GONZALEZ, et CERTIFICATION OF HANDEL T.
als. DESTINVIL IN SUPPORT OF
DEFENDANT, CITY OF NEWARK’S
Defendants OPPOSITION TO PLAINTIFF’S
MOTION TO COMPEL PRODUCTION
OF DOCUMENTS PURSUANT TO
N,J.R. 4:23-5(c)
Handel T. Destinvil, of full age, hereby certifies and says:
1 lam an Attorney-at-law of the State of New J ersey, Assistant Corporation
Counsel at the City of Newark — Departmentof Law, and counsel for the Defendant,
City of Newark. As an employee of the City of Newark, working within the City of
Newark — Departmentof Law, | am fully familiar with the operations of this office.
2 | am the attorney responsible for the defense of this matter. | make this
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of2 Trans ID: LCV2023501728
certification in support of Defendant, City of Newark’s opposition to Plaintiff's Motion to
Compel Production of Documents, pursuantto N.J .R. 4:23-5(c), which motion is
returnable on Friday, J anuary 6, 2023.
3 Attached hereto as “Exhibit A” is a true and accurate copy of an email
communication from Handel T. Destinvil, Esq., Assistant Corporation Counsel, City of
Newark — Departmentof Law, to J oel |. Rachmiel, Esq. (Feb. 9, 2023, 17:31
EST)(original on file with author).
I certify that the foregoing statements made by me are true. | am aware that if any
of these statements are willfully false, | am subjectto punishment.
Kenyatta K. Stewart, Corporation Counsel
City of Newark — Department of Law
Attorney for Defendant, City of Newark
By: [s| Handel
Pl Nanded SF,@. Deotinnil
Arete
Handel T. Destinvil, Esq.
Assistant Corporation Counsel
Dated: February 9, 2023
ESX-L-004552-22 02/09/2023 6:12:21 PM Pglof18 Trans ID: LCV2023501728
EXHIBIT A
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of18 Trans ID: LCV2023501728
Destinvil, Handel
From: Destinvil, Handel
Sent: Thursday, February 9, 2023 5:31 PM
To: Joel Rachmiel
Subject: City Response to Pl. Dec. 19, 2022 Notice to Produce - Ronald Ricketts, ESX-L-4552-22
Attachments: City Notice to Produce Filing Letter to Pl. - Ricketts.pdf; City Notice to Produce to PI. -
Ricketts.pdf; July 29, 2022 Notice of Claim.pdf
Importance: High
Counsel, good afternoon, please find attached the City’s responses to Plaintiff's December 19, 2022
Notice to Produce, with accompanying cover letter, and exhibit.
Thank you,
Handel
Handel T. Destinvil
Assistant Litigation Section Chief
City of Newark
Department of Law
920 Broad Street, Room 316
Newark, New Jersey 07102
973-733-3114
973-733-5394 Fax
destinvilh @ci.newark.nj.us
OF NEF
Ky
BS
cl
Q ReonnTe®
Notice: This communication, including attachments, may contain information that is confidential and
protected by the attorney/client or other privileges. It constitutes non-public information intended to be
conveyed only to the designated recipient(s). If the reader or recipient of this communication is not
the intended recipient, an employee or agent of the intended recipient who is responsible for
delivering it to the intended recipient, or you believe that you have received this communication in
error, please notify the sender immediately by return e-mail and promptly delete this e-mail, including
attachments without reading or saving them in any manner. The unauthorized use, dissemination,
distribution, or reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client or other
privilege.
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg3o0f18 Trans ID: LCV2023501728
FNEWARK Mayor Ras J. Baraka
Department of Law A City We Can All Believe In
Kenyatta K. Stewart, Esq., Handel T. Destinvil, Esq.
Corporation Counsel Assistant Corporation Counsel
920 Broad Street, Room 316 desti In@ci.n rk.nj.us
Newark, New Jersey 07102 Dir: (973) 733-3114
Office: (973)733-3880
Fax: (973) 733-5394
February 9, 2023
Via Electronic Mail to joelrachmiel@aol.com
Joel |. Rachmiel, Esq
46 Broom Drive
Florham Park, New Jersey 07932
Re: Ronald Ricketts v. Ofc. Samuel C. Gonzalez, et als
DOCKET NO. ESX-L-4561-22
Dear Counsel
The undersigned represents Defendant, City of Newark (“City”), in the above-
captioned matter. Please find enclosed the City's responses to Plaintiff's December 19.
2022 Notice to Produce as to the City. Apologies for the delay.
Please feel free to contact me directly by telephone at (973) 733-3114 or via
email to destinvilh@ci.newark.nj.us if you have any additional questions or
comments.
Very truly yours,
Kenyatta K. Stewart,
Corporation Counsel
By: Hondel-T.—Destirvsie——
et
Handel T. Destinvil, Esq.
Assistant Corporation Counsel
Enc.
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg4of18 Trans ID: LCV2023501728
KENYATTA K. STEWART, CORPORATION COUNSEL
CITY OF NEWARK — DEPARTMENT OF LAW
920 Broad Street, Room 316
Newark, New Jersey 07102
Attorney for Defendant, City of Newark
By: Handel T. Destinvil, Esq.
destinvilh@ci.newark.nj.u
Assistant Corporation Counsel
NJ Bar ID# 129102015
Telephone (973) 733-3114
Facsimile (973) 733-5394
RONALD RICKETTS,
Plaintiff, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
Vv. DOCKET NO. ESX-L-4561-22
OFFICER SAMUEL C. GONZALEZ, et Civil Action
als.
RESPONSE TO PLAINTIFF’S
DECEMBER 19, 2022 NOTICE TO
Defendants. PRODUCE
TO: Joel |. Rachmiel, Esq.
46 Broom Drive
Florham Park, New Jersey 07932
Attorney for Plaintiff
Counsel:
Defendant, City of Newark hereby responds to Plaintiff's December 19, 2022
Demand for Production of Documents as follows.
KENYATTA K. STEWART, CORPORATION COUNSEL
CITY OF NEWARK - DEPARTMENT OF LAW
Attorney for Defendant, City of Newark
By: Isl Handel TS. Deatinwil
Handel T. Destinvil, Esq.
Assistant Corporation Counsel
Dated: February 9, 2023
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg5of18 Trans ID: LCV2023501728
CERTIFICATION
| hereby certify (or aver) that | have reviewed the document production request and that
| have made or caused to be made a good faith search for documents responsive to the
request.
| further certify (or aver) that as of this date, to the best of my knowledge and
information, the production is complete and accurate based on ( x ) my personal
knowledge and/or ( x ) information provided by others. | acknowledge my continuing
obligation to make a good faith effort to identify additional documents that are
responsive to the request and to promptly serve a supplemental written response and
production of such documents, as appropriate, as | become aware of them. The
following is a list of the identity and source of knowledge of those who provided
information to me:
Newark Department of Public Safety, Newark Police Division, Office of
Professional Standards
Kenyatta K. Stewart, Corporation Counsel
City of Newark — Department of Law
Attorney for Defendant, City of Newark
By:__/s/ Handel FT. Destinwl
Handel T. Destinvil, Esq.
Assistant Corporation Counsel
Dated: February 9, 2023
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg6of18 Trans ID: LCV2023501728
RESPONSES
1. Copies of any body camera video recordings of Newark Police Officer
Samuel C. Gonzalez, Newark Police Sgt. Miguel Silva, or any other Newark
Police officer or any other individual who recorded the events leading up to and
including the seizure of plaintiff's vehicle on or about July 13, 2022, regardless
of what they show or who possesses them.
RESPONSE: The City objects to this demand for production pursuant to the
“Internal Affairs Policy & Procedures” of the Office of the New Jersey
Attorney General (December 2019)(hereinafter “AG Guidelines”).
Please be advised that the Newark Department of Public Safety, Newark
Police Division, Office of Professional Standards (“Office”) has opened a
concurrent investigation into the allegations of misconduct set forth in
Plaintiff's August 4, 2022 Complaint. Upon information and belief, the
investigation remains ongoing and is docketed as IOP 2022-0627.
Paragraph 9.6.1 of the AG Guidelines provides that “[t]he contents of an
internal investigation case file, including the original complaint, shall be
retained in the internal affairs function and clearly marked as confidential.”
(emphasis added).
Paragraph 1.0.14 of the AG Guidelines Law separately provides that “[I]Jaw
enforcement agencies that fail to comply with the policies and procedures
contained within this document may be subject to the same sanctions
arising from any other violation of an AG Directive, including supersession
of an agency’s law enforcement functions by the Attorney General.”
For the aforesaid reasons and authorities cited, the City asserts privilege
as to the “body camera video recordings.
Copies of any photographs or surveillance video recordings regardless
of what they show or who possesses them concerning anything about this case
and the seizure of plaintiff's vehicle on or about July 13, 2022.
RESPONSE: The City objects to this demand for production for the same
reasons and authorities cited above in response to Paragraph 1.
Any documents or other items regardless of what they show or who
possesses them concerning anything about this case and the seizure of
plaintiff's vehicle on or about July 13, 2022.
RESPONSE: The City objects to this demand for production for the same
reasons and authorities cited above in response to Paragraph 1. In
addition, the City objects to this demand for production on the grounds
that a request for “[aJny documents or other items regardless of what they
show or who possesses them concerning anything about this case and the
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg7of18 Trans ID: LCV2023501728
seizure of plaintiff's vehicle on or about July 13, 2022” is unduly
burdensome on its face and overbroad.
Any documents, writing or other communication that contain any
statements or communications from plaintiff whether signed or unsigned.
RESPONSE: Please see attached Plaintiff's July 29, 2022 specialized Notice
of Claim to the City.
Any statement, writing or other document which contains any
statements of any party to this action regardless of what they show or who
possesses them concerning anything about this case and the seizure of
plaintiff's vehicle on or about July 13, 2022.
RESPONSE: The City objects to this demand for production for the same
reasons and authorities cited above in response to Paragraph 1. In
addition, the City objects to this demand for production on the grounds
that a request for “[aJny statement, writing or other document which
contains any statements of any party to this action regardless of what they
show or who possesses them concerning anything about this case and the
seizure of plaintiff's vehicle on or about July 13, 2022” is unduly
burdensome on its face and overbroad.
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg 8of18 Trans ID: LCV2023501728
NOTICE OF CLAIM FOR DAMAGES AGAINST THE CITY OF NEWARK
FOR AND TO: CITY OF NEWARK OATE OF CLAIM,
DEPARTMENT OF LAW
920 BROAD STREET —CITY HALL
NEWARK, NY 07102
NOTE: THIS CLAIM FORM MUST BE FILED WITHIN 90 DAYS OF THE ACCIDENT/INCIDENT/OCCURRENCE
OR YOUR CLAIM MAY BE BARRED BY THE NEW JERSEY TORT CLAIM ACT, NJS.A. 59:1-1, et seq.
2, CLAIMANT:
R leha7TS honteop CC 2L48fS.
Last Name
“legis ST.
Malling address if other than street address
Wewakle ux OFZ ge =XK= ZY
* State - Sosial Security Number 7
{f notice and correspondence in connection with’this claim are to be sent to 2 person other than
claimant, complete item #2.
A doe, Ft Rasta 1€c S52
FLO,
Malling Address ary State
Relationship to claim: Attorney-at-
Explain Relationship
3. The occurrence or accident which gave cise to this claiin:
pha faa M3YE Py
Time
3a. If you allege that dangerous conditions contributed to your Injury or damages indicate
exact location of sald condition with reference to fixed object by drawing a diagram.
Municipality Exact location of the occurrence
- bmnecee
ww whe
REC'B NEWARK LAW DEPT
RUG 22°22 end 2
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg9of18 Trans ID: LCV2023501728
‘Sb. Orawa dlagram (in the space Provider’) showing the street plan
at the focatior. of the accident.
Label each street and show the direction of travel of. =n vehicle before and after contact.
——— one woe
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— teenta
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as aan ain aetna eee
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3c, Describe fant or. accurrenice fappened. If 4 diagram will assist your explanatio
please abo tay Ba
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3d. Sta address of the City agency dragencies which you claim caused yau
et damages,
eh 4)
~ubLLIOZ Def, nie
3e. State any.n of the city ioloyads who you clair were a ait, including any
information that Ist in ldentifying and locating them.
LO Sane. Se
Sale tni e
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ome name:
sub
anes
ESX-L-004552-22 02/09/2023 6:12:21PM Pg10of18 Trans ID: LCV2023501728
L3f. State the negiigence or vont acts of the city agency and City ennlayees which
caused
your. damages.
weep: SLIP
>. Alp
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sis and veh
af
State the names ofall alice officers, and pofice departments who investigated the accident.
Ei
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bite a copy of, Police Report or CentralSc nalhinNuinber:
BNO. Zt 2120s OTL Ane be ougp tie sep in
*Clalm folDamagds (heck svforne bléck) f
b eure PER EV PONCE RECEIPT.
«TOWN. pale. REL Pr
ae. Person nary () Property Damage
Other Bat In detalat EE. AWS. Zé,
eh
you dl Personal |
ESX-L-004552-22 02/09/2023 6:12:21PM Pg1lof18 Trans ID: LCV2023501728
:
1 Describe your injuries resulting from this accident or occurrence,
n Do you daim permanent disabliity resulting from this injury?
“YES No
iyes, describe the injuries Believed to be permanent.
Loe rt
2
pale a ‘
mM. Foi each) dspla doctor m other practitioner rendering treatment examination, ‘or
ce
diagno: rvice;.
Be
‘Nami Hospital; Doctor.or other ]’Address ‘Taniount
me Faclti
“Amount™
-|'Charg2to-| pald
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te
iV. you claim toss wes or Incame as the result of heyy ste .
—
of Employer “Tareas oF Ene
Your Occ Baten decan employed at this job
ae
te of Pay. 7
tateseT absenes from wor
a al date Itstiff out of =e ‘expucted date of return
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg12of18 Trans ID: LCV2023501728
Note: If you claimed loss of | income arising fo self. emple ent or other wages, attach
tatcalat showing the be F Your cal tlon of lost incom
Poy
5. Set forth any and all other damag
gate
ak,
Sa. if ydu claim propa any
i Describe the property
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ESX-L-004552-22 02/09/2023 6:12:21PM Pg13o0f18 Trans ID: LCV2023501728
6. Sf you claim vehicle damage:
Description of your Vehicle involved in accident.
Year. Make. Madel_ Lic, Plate No. a
Driver's Name, Jic.No.
Address, = Clty. State_ Zip. Ss
Owner's Name and Address
Insursinge 60, 3, Policy No.
Insurance Co, Adaess ae
Dawages to vehicle: :
3
7 &a. Set forth In il ali the other Items of loss or damages claimed by you and the method by
Vc.
whit vou maide cal lation.
res ho 8
ia fy
tenn
ee corns wore
ney
wave rnbe
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eb. f He ono dai
sentra fF the testo expenses claimed in this
:
7 ve ye de a cl inst any
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notice’,
“yeu bes es and addresets of al Persons and Instirance companies against whom
you have made ‘such clairn
a
8 Fhe
ESX-L-004552-22 02/09/2023 6:12:21PM Pg14o0f18 Trans ID: LCV2023501728
8, Are any of the losses or expenses claimed hereln covered by any policy or Insurance? We
For each such policy, state the name and address of the insurance company, policy number, and
benefits paid or payable.
THE FOLLOWING STEMS MUST BE SUBIMITTED WITH THIS NOTICE OF CLAIM
(2) Coples of itemized bills for each medical expense ant! other losses and expenses claimed.
(2) Full copiesof all appraisals and estimates of property damage claimed by you,
(3) Copies of all written reports of all expert witnesses and treating physicians,
{4) A letter from your employer verifying your wages, if self- employed a statement showing the
calculation of your claimed lost income:
HEREBY CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, THAT THE ATTACHED:
STATEMENTS, BILLS, REPORTS AND DOCUMENTS ARE THE ONLY ONIS KNOWNTO ME TO BE.IN
EXISTENCE AT THIS TIME. t AM AWARE THAT IF ANY STATEMNT MADE HEREIN IS WILFULLY FALSE OR
FRAUDULENT, THAT | WILL BE SUBJECT TO PUNISHMNENT PROVIDED BY. LAW.
paren: 2/99 ial)
Claimant or filling clainy on behalf of claimant
CLE, RacHa tet.
ATTY AT RW
PLEASE BE ADVISED THAT IN ORDER FOR YOUR CLAIM TO BE CONSIDERED, YOU MUST ALSO COMPLETE
AND SIGN THE ATTACHED AUTHORIZATION TO DISCLOSE HEALTH INFORMANTION FORMS AS
TO EACH
MEDICAL PROVIDER EMNTIONED IN THIS CLAIM FORM.
- bomen
ESX-L-004552-22 02/09/2023 6:12:21 PM Pg15of18 Trans ID: LCV2023501728
POLICE DEPARTMENT _ PROPERTY EVIDENCE
oN RECEIPT NEWARK, NJ
[FOUN OR RECOVERED By (2) SECTOR conan ay DISTRICT ha RAL COMPLAINT NO
| 599 UNIT
ti Tow
13h SOUTH STH 22031005
TIME
249 DATE FOUN OR
i
91 DEWEY ST, NEWARK NJ 07112
a -
Jul 15, 2022 17:00
| eyonnen Stee “| {6 ADDRESS ANG 21P COD: 13) TELEPHONE NO
“RICKETTS, RONALD G 187 DEWEY ST, NEWARKNJ 07112-1360 a
BRIEF EXPLAIN\T OM OF FINUINGS AN RECOVERY
ime FOLLOWING CURRENCY IS PERSONAL PROPERTY RECOVERED FROM A SEARCH WARRANT.
‘TWELVE (12) $100's = $1,200.00...
—
712) PRISONER (A) CANIMAER “AGE DAIL OF ARREST (13) ENVELOPE CONTROL HURABER
1
— - |__
“panes CHARGES:
t
PRISONER (8) CANUMSER AGE DATE OF ARREST 7 NVELOPE CONTROL KUMBER
peer
ADDRESS CHARGES
PRISONER(C) CA NUMBER AGE DATE OF ARREST (73) ENVELOPE CONTROL NUMBER
ADORESS: CHARGES
PRISONER (0) CAHUMBER AGE DATE OF ARREST (15) ENVELOPE CONTROL NUMBER
‘ADDRESS CHARGES:
14 116) on (18)
ITEM oT EVIDENCE SOURCE ARTICLE DESCRIPTION ESTIMATED CASH VALUE
12 TWELVE (12) $100'S = $1,200.00
1a FOURTEEN (14) $1'S =$14.00
TOTAL = $1,214.00
a -
¥°9) NARG FIELD TEST BY COMMANL COCAINE RESULTS HEROIN RESULIS
(20) PROPERTY (Clarrest-evinence (Jrouno Cloecevenis ([]stoven [Z)PERSONAL PROPERTY CF PRISONER
(21) CURRENCY JEWELRY FURS GLOTINNG BISCE) LANEOUS TOTAL TOTAL NO OF PROP 28 EVIO RECEIPTS
aya OF a RECEIPTS
(23) OFFICE! COMMAND, (24} SUPERIOR RECEIVING REC ‘COMMAND
PO FORT! 11005 STH LT REYES, JOEL 90%
(25) PROPERTY LOCATION
BELOW FOR PROPERTY ROOM USE ONLY - RECORD OF PROPERTY MOVEMENT
(26) PROSECUTOR'S RELEASE
SeNr
(28) item
RECEIVED
PRIN
PHOTO TAKEN BY DATE OK TO RELCASE ITEMS BY
ME, ‘SIGNATURE
7) sicuafl RE
TO
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ENVELOPE NUMBER / COMMENTS
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PROP.
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Busine 4 Ras ld Brwerrs
BUT pe he
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| HEREBY ACKNOWLEDGE RECEIVING FROM THE POLICE DEPARTMENT THE PROPERTY LISTED BELOW
pe I 0d
AQORESS:
KE LL 4
ITE NO ate
Re AALG
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ESX-L-004552-22 02/09/2023 6:12:21 PM Pg16of18 Trans ID: LCV2023501728
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ESX-L-004552-22 02/09/2023 6:12:21PM Pg17of18 Trans ID: LCV2023501728
. DENTE BROS.
Towing, Inc.
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(973) 344-3100
Newark, NJ 07105
(973) 465-1062 DENTStE BROT HERS TORING
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ESX-L-004552-22 02/09/2023 6:12:21PM Pglof2 Trans ID: LCV2023501728 NEWARK Mayor Ras J. Baraka Department of Law A City We Can All Believe In Kenyatta K. Stewart, Esq., Handel T. Destinvil, Esq. Corporation Counsel Assistant Corporation Counsel 920 Broad Street, Room 316 destinvilh@ ci.newark.nj.u: Newark, New J ersey 07102 Dir. (973) 733-3114 Office: (973)733-3880 Fax: (973) 733-5394 February 9, 2023 Via Electronic Filing Chambers of the Hon. Annette Scoca, J .S.C. Superior Court of New J ersey, Essex Vicinage, Law Division Hall of Records, Chambers 304 465 Dr. Martin Luther King, J r. Boulevard Newark, NJ 07102 Re: Ronald Ricketts v. Officer Samuel G. Gonzalez, et als. DOCKET NO. ESX-L-4552-22 Your Honor: The undersigned represents Defendant, City of Newark (“City”) in the above- captioned matter. OnJ anuary 30, 2023, Plaintiff, Ronald Ricketts (“Plaintiff”) filed a Motion to Compel Production of Documents as to the City, pursuantto N.J .R. 4:23-5(c). (eCourts Transaction ID: LCV2023400184). Specifically, Plaintiff sought production of responses to Plaintiff's December 19, 2022 Notice to Produce, for which responses were due on J anuary 23, 2023. See Rachmiel J an. 30, 2023 Cert 94 1-9. The undersigned apologizes to the Court and fellow counsel for the delay in production. However, the Court can take judicial notice, pursuantto N.J .R.E. 201(b)(4), of the fact that today, at 5:31 PM EST, the City served responses to Plaintiff's Notice to Produce. See Ex. A at 1-17, as attached to Destinvil Feb. 9, 2023 Cert. Accordingly, ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of2 Trans ID: LCV2023501728 Plaintiff's Motion to Compel Production of Documents can be denied as moot. See Greenfield v. New J ersey Dep't of Corr., 382 N.J. Super. 254, 257-58 (App. Div. 2006)(“An issue is ‘moot’ when the decision sought in a matter, when rendered, can have no practical effect on the existing controversy.”)(internal quotation and citation omitted). CONCLUSION For the aforesaid reasons and authorities cited herein, the Court should deny Plaintiff's J anuary 30, 2023 Motion to Compel Production of Documents as moot. Respectfully submitted, Kenyatta K. Stewart Corporation Counsel By: Bendel-FT—Destersed—€§ (St Handel T. Destinvil, Esq. Assistant Corporation Counsel Enc. cc: Joell. Rachmiel, Esq. Via Electronic Filing: joelrachmiel@ aol.com ESX-L-004552-22 02/09/2023 6:12:21PM Pglof2 Trans ID: LCV2023501728 KENYATTA K. STEWART, CORPORATION COUNSEL CITY OF NEWARK — DEPARTMENT OF LAW 920 Broad Street, Room 316 Newark, NewJ ersey 07102 Attorney for Defendant, City of Newark By: Handel T. Destinvil, Esq. destinvilh@ ci.newark.nj.us Assistant Corporation Counsel NJ Bar ID#129102015 Telephone (973) 733-3114 Facsimile (973) 733-5394 RONALD RICKETTS, SUPERIOR COURT OF NEW J ERSEY LAW DIVISION: ESSEX COUNTY Plaintiff, DOCKET NO. ESX-L-4552-22 Vv. Civil Action OFFICER SAMUEL C. GONZALEZ, et CERTIFICATION OF HANDEL T. als. DESTINVIL IN SUPPORT OF DEFENDANT, CITY OF NEWARK’S Defendants OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS PURSUANT TO N,J.R. 4:23-5(c) Handel T. Destinvil, of full age, hereby certifies and says: 1 lam an Attorney-at-law of the State of New J ersey, Assistant Corporation Counsel at the City of Newark — Departmentof Law, and counsel for the Defendant, City of Newark. As an employee of the City of Newark, working within the City of Newark — Departmentof Law, | am fully familiar with the operations of this office. 2 | am the attorney responsible for the defense of this matter. | make this ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of2 Trans ID: LCV2023501728 certification in support of Defendant, City of Newark’s opposition to Plaintiff's Motion to Compel Production of Documents, pursuantto N.J .R. 4:23-5(c), which motion is returnable on Friday, J anuary 6, 2023. 3 Attached hereto as “Exhibit A” is a true and accurate copy of an email communication from Handel T. Destinvil, Esq., Assistant Corporation Counsel, City of Newark — Departmentof Law, to J oel |. Rachmiel, Esq. (Feb. 9, 2023, 17:31 EST)(original on file with author). I certify that the foregoing statements made by me are true. | am aware that if any of these statements are willfully false, | am subjectto punishment. Kenyatta K. Stewart, Corporation Counsel City of Newark — Department of Law Attorney for Defendant, City of Newark By: [s| Handel Pl Nanded SF,@. Deotinnil Arete Handel T. Destinvil, Esq. Assistant Corporation Counsel Dated: February 9, 2023 ESX-L-004552-22 02/09/2023 6:12:21 PM Pglof18 Trans ID: LCV2023501728 EXHIBIT A ESX-L-004552-22 02/09/2023 6:12:21 PM Pg2of18 Trans ID: LCV2023501728 Destinvil, Handel From: Destinvil, Handel Sent: Thursday, February 9, 2023 5:31 PM To: Joel Rachmiel Subject: City Response to Pl. Dec. 19, 2022 Notice to Produce - Ronald Ricketts, ESX-L-4552-22 Attachments: City Notice to Produce Filing Letter to Pl. - Ricketts.pdf; City Notice to Produce to PI. - Ricketts.pdf; July 29, 2022 Notice of Claim.pdf Importance: High Counsel, good afternoon, please find attached the City’s responses to Plaintiff's December 19, 2022 Notice to Produce, with accompanying cover letter, and exhibit. Thank you, Handel Handel T. Destinvil Assistant Litigation Section Chief City of Newark Department of Law 920 Broad Street, Room 316 Newark, New Jersey 07102 973-733-3114 973-733-5394 Fax destinvilh @ci.newark.nj.us OF NEF Ky BS cl Q ReonnTe® Notice: This communication, including attachments, may contain information that is confidential and protected by the attorney/client or other privileges. It constitutes non-public information intended to be conveyed only to the designated recipient(s). If the reader or recipient of this communication is not the intended recipient, an employee or agent of the intended recipient who is responsible for delivering it to the intended recipient, or you believe that you have received this communication in error, please notify the sender immediately by return e-mail and promptly delete this e-mail, including attachments without reading or saving them in any manner. The unauthorized use, dissemination, distribution, or reproduction of this e-mail, including attachments, is prohibited and may be unlawful. Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client or other privilege. ESX-L-004552-22 02/09/2023 6:12:21 PM Pg3o0f18 Trans ID: LCV2023501728 FNEWARK Mayor Ras J. Baraka Department of Law A City We Can All Believe In Kenyatta K. Stewart, Esq., Handel T. Destinvil, Esq. Corporation Counsel Assistant Corporation Counsel 920 Broad Street, Room 316 desti In@ci.n rk.nj.us Newark, New Jersey 07102 Dir: (973) 733-3114 Office: (973)733-3880 Fax: (973) 733-5394 February 9, 2023 Via Electronic Mail to joelrachmiel@aol.com Joel |. Rachmiel, Esq 46 Broom Drive Florham Park, New Jersey 07932 Re: Ronald Ricketts v. Ofc. Samuel C. Gonzalez, et als DOCKET NO. ESX-L-4561-22 Dear Counsel The undersigned represents Defendant, City of Newark (“City”), in the above- captioned matter. Please find enclosed the City's responses to Plaintiff's December 19. 2022 Notice to Produce as to the City. Apologies for the delay. Please feel free to contact me directly by telephone at (973) 733-3114 or via email to destinvilh@ci.newark.nj.us if you have any additional questions or comments. Very truly yours, Kenyatta K. Stewart, Corporation Counsel By: Hondel-T.—Destirvsie—— et Handel T. Destinvil, Esq. Assistant Corporation Counsel Enc. ESX-L-004552-22 02/09/2023 6:12:21 PM Pg4of18 Trans ID: LCV2023501728 KENYATTA K. STEWART, CORPORATION COUNSEL CITY OF NEWARK — DEPARTMENT OF LAW 920 Broad Street, Room 316 Newark, New Jersey 07102 Attorney for Defendant, City of Newark By: Handel T. Destinvil, Esq. destinvilh@ci.newark.nj.u Assistant Corporation Counsel NJ Bar ID# 129102015 Telephone (973) 733-3114 Facsimile (973) 733-5394 RONALD RICKETTS, Plaintiff, SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY Vv. DOCKET NO. ESX-L-4561-22 OFFICER SAMUEL C. GONZALEZ, et Civil Action als. RESPONSE TO PLAINTIFF’S DECEMBER 19, 2022 NOTICE TO Defendants. PRODUCE TO: Joel |. Rachmiel, Esq. 46 Broom Drive Florham Park, New Jersey 07932 Attorney for Plaintiff Counsel: Defendant, City of Newark hereby responds to Plaintiff's December 19, 2022 Demand for Production of Documents as follows. KENYATTA K. STEWART, CORPORATION COUNSEL CITY OF NEWARK - DEPARTMENT OF LAW Attorney for Defendant, City of Newark By: Isl Handel TS. Deatinwil Handel T. Destinvil, Esq. Assistant Corporation Counsel Dated: February 9, 2023 ESX-L-004552-22 02/09/2023 6:12:21 PM Pg5of18 Trans ID: LCV2023501728 CERTIFICATION | hereby certify (or aver) that | have reviewed the document production request and that | have made or caused to be made a good faith search for documents responsive to the request. | further certify (or aver) that as of this date, to the best of my knowledge and information, the production is complete and accurate based on ( x ) my personal knowledge and/or ( x ) information provided by others. | acknowledge my continuing obligation to make a good faith effort to identify additional documents that are responsive to the request and to promptly serve a supplemental written response and production of such documents, as appropriate, as | become aware of them. The following is a list of the identity and source of knowledge of those who provided information to me: Newark Department of Public Safety, Newark Police Division, Office of Professional Standards Kenyatta K. Stewart, Corporation Counsel City of Newark — Department of Law Attorney for Defendant, City of Newark By:__/s/ Handel FT. Destinwl Handel T. Destinvil, Esq. Assistant Corporation Counsel Dated: February 9, 2023 ESX-L-004552-22 02/09/2023 6:12:21 PM Pg6of18 Trans ID: LCV2023501728 RESPONSES 1. Copies of any body camera video recordings of Newark Police Officer Samuel C. Gonzalez, Newark Police Sgt. Miguel Silva, or any other Newark Police officer or any other individual who recorded the events leading up to and including the seizure of plaintiff's vehicle on or about July 13, 2022, regardless of what they show or who possesses them. RESPONSE: The City objects to this demand for production pursuant to the “Internal Affairs Policy & Procedures” of the Office of the New Jersey Attorney General (December 2019)(hereinafter “AG Guidelines”). Please be advised that the Newark Department of Public Safety, Newark Police Division, Office of Professional Standards (“Office”) has opened a concurrent investigation into the allegations of misconduct set forth in Plaintiff's August 4, 2022 Complaint. Upon information and belief, the investigation remains ongoing and is docketed as IOP 2022-0627. Paragraph 9.6.1 of the AG Guidelines provides that “[t]he contents of an internal investigation case file, including the original complaint, shall be retained in the internal affairs function and clearly marked as confidential.” (emphasis added). Paragraph 1.0.14 of the AG Guidelines Law separately provides that “[I]Jaw enforcement agencies that fail to comply with the policies and procedures contained within this document may be subject to the same sanctions arising from any other violation of an AG Directive, including supersession of an agency’s law enforcement functions by the Attorney General.” For the aforesaid reasons and authorities cited, the City asserts privilege as to the “body camera video recordings. Copies of any photographs or surveillance video recordings regardless of what they show or who possesses them concerning anything about this case and the seizure of plaintiff's vehicle on or about July 13, 2022. RESPONSE: The City objects to this demand for production for the same reasons and authorities cited above in response to Paragraph 1. Any documents or other items regardless of what they show or who possesses them concerning anything about this case and the seizure of plaintiff's vehicle on or about July 13, 2022. RESPONSE: The City objects to this demand for production for the same reasons and authorities cited above in response to Paragraph 1. In addition, the City objects to this demand for production on the grounds that a request for “[aJny documents or other items regardless of what they show or who possesses them concerning anything about this case and the ESX-L-004552-22 02/09/2023 6:12:21 PM Pg7of18 Trans ID: LCV2023501728 seizure of plaintiff's vehicle on or about July 13, 2022” is unduly burdensome on its face and overbroad. Any documents, writing or other communication that contain any statements or communications from plaintiff whether signed or unsigned. RESPONSE: Please see attached Plaintiff's July 29, 2022 specialized Notice of Claim to the City. Any statement, writing or other document which contains any statements of any party to this action regardless of what they show or who possesses them concerning anything about this case and the seizure of plaintiff's vehicle on or about July 13, 2022. RESPONSE: The City objects to this demand for production for the same reasons and authorities cited above in response to Paragraph 1. In addition, the City objects to this demand for production on the grounds that a request for “[aJny statement, writing or other document which contains any statements of any party to this action regardless of what they show or who possesses them concerning anything about this case and the seizure of plaintiff's vehicle on or about July 13, 2022” is unduly burdensome on its face and overbroad. ESX-L-004552-22 02/09/2023 6:12:21 PM Pg 8of18 Trans ID: LCV2023501728 NOTICE OF CLAIM FOR DAMAGES AGAINST THE CITY OF NEWARK FOR AND TO: CITY OF NEWARK OATE OF CLAIM, DEPARTMENT OF LAW 920 BROAD STREET —CITY HALL NEWARK, NY 07102 NOTE: THIS CLAIM FORM MUST BE FILED WITHIN 90 DAYS OF THE ACCIDENT/INCIDENT/OCCURRENCE OR YOUR CLAIM MAY BE BARRED BY THE NEW JERSEY TORT CLAIM ACT, NJS.A. 59:1-1, et seq. 2, CLAIMANT: R leha7TS honteop CC 2L48fS. Last Name “legis ST. Malling address if other than street address Wewakle ux OFZ ge =XK= ZY * State - Sosial Security Number 7 {f notice and correspondence in connection with’this claim are to be sent to 2 person other than claimant, complete item #2. A doe, Ft Rasta 1€c S52 FLO, Malling Address ary State Relationship to claim: Attorney-at- Explain Relationship 3. The occurrence or accident which gave cise to this claiin: pha faa M3YE Py Time 3a. If you allege that dangerous conditions contributed to your Injury or damages indicate exact location of sald condition with reference to fixed object by drawing a diagram. Municipality Exact location of the occurrence - bmnecee ww whe REC'B NEWARK LAW DEPT RUG 22°22 end 2 ESX-L-004552-22 02/09/2023 6:12:21 PM Pg9of18 Trans ID: LCV2023501728 ‘Sb. Orawa dlagram (in the space Provider’) showing the street plan at the focatior. of the accident. Label each street and show the direction of travel of. =n vehicle before and after contact. ——— one woe Sotte hera r n e — teenta naesinne as aan ain aetna eee Ane sry 3c, Describe fant or. accurrenice fappened. If 4 diagram will assist your explanatio please abo tay Ba NE ee (oe. Mtheepge 2. LZ bs emer Nie. te 1 ea Te ea Ata tales. CAR rar gs LEG pb LY:lisa i 3d. Sta address of the City agency dragencies which you claim caused yau et damages, eh 4) ~ubLLIOZ Def, nie 3e. State any.n of the city ioloyads who you clair were a ait, including any information that Ist in ldentifying and locating them. LO Sane. Se Sale tni e meee LG thee Elbe ome name: sub anes ESX-L-004552-22 02/09/2023 6:12:21PM Pg10of18 Trans ID: LCV2023501728 L3f. State the negiigence or vont acts of the city agency and City ennlayees which caused your. damages. weep: SLIP >. Alp aia SOE, Lo 34 eee: CAE RERY Rule ye Tope 20g Be PO JE Ane ‘Shee EES ade Aetmdlia 84000 Ww). CASH Wile wip BEC Ld Tec AR :zs 48 tate the name addrsit al witnesses to theScent or18 frence, 3 sis and veh af State the names ofall alice officers, and pofice departments who investigated the accident. Ei hetmme ro me bite a copy of, Police Report or CentralSc nalhinNuinber: BNO. Zt 2120s OTL Ane be ougp tie sep in *Clalm folDamagds (heck svforne bléck) f b eure PER EV PONCE RECEIPT. «TOWN. pale. REL Pr ae. Person nary () Property Damage Other Bat In detalat EE. AWS. Zé, eh you dl Personal | ESX-L-004552-22 02/09/2023 6:12:21PM Pg1lof18 Trans ID: LCV2023501728 : 1 Describe your injuries resulting from this accident or occurrence, n Do you daim permanent disabliity resulting from this injury? “YES No iyes, describe the injuries Believed to be permanent. Loe rt 2 pale a ‘ mM. Foi each) dspla doctor m other practitioner rendering treatment examination, ‘or ce diagno: rvice;. Be ‘Nami Hospital; Doctor.or other ]’Address ‘Taniount me Faclti “Amount™ -|'Charg2to-| pald Gate Insuira te iV. you claim toss wes or Incame as the result of heyy ste . — of Employer “Tareas oF Ene Your Occ Baten decan employed at this job ae te of Pay. 7 tateseT absenes from wor a al date Itstiff out of =e ‘expucted date of return ESX-L-004552-22 02/09/2023 6:12:21 PM Pg12of18 Trans ID: LCV2023501728 Note: If you claimed loss of | income arising fo self. emple ent or other wages, attach tatcalat showing the be F Your cal tlon of lost incom Poy 5. Set forth any and all other damag gate ak, Sa. if ydu claim propa any i Describe the property ‘ tT x35, S i" a ¥. tr Po N= res tin nay by ie i Date prop acquired Value of property a a€ time dfaceident wel a dan ‘i 1G Hi 7 Tit wad He Te ae Be {} ()inb. 0, hen as ta My imi FRI Pate ee x7 t FoI in detallthe toss Cal jou for ty cat ESX-L-004552-22 02/09/2023 6:12:21PM Pg13o0f18 Trans ID: LCV2023501728 6. Sf you claim vehicle damage: Description of your Vehicle involved in accident. Year. Make. Madel_ Lic, Plate No. a Driver's Name, Jic.No. Address, = Clty. State_ Zip. Ss Owner's Name and Address Insursinge 60, 3, Policy No. Insurance Co, Adaess ae Dawages to vehicle: : 3 7 &a. Set forth In il ali the other Items of loss or damages claimed by you and the method by Vc. whit vou maide cal lation. res ho 8 ia fy tenn ee corns wore ney wave rnbe Baa : eb. f He ono dai sentra fF the testo expenses claimed in this : 7 ve ye de a cl inst any $ ‘ notice’, “yeu bes es and addresets of al Persons and Instirance companies against whom you have made ‘such clairn a 8 Fhe ESX-L-004552-22 02/09/2023 6:12:21PM Pg14o0f18 Trans ID: LCV2023501728 8, Are any of the losses or expenses claimed hereln covered by any policy or Insurance? We For each such policy, state the name and address of the insurance company, policy number, and benefits paid or payable. THE FOLLOWING STEMS MUST BE SUBIMITTED WITH THIS NOTICE OF CLAIM (2) Coples of itemized bills for each medical expense ant! other losses and expenses claimed. (2) Full copiesof all appraisals and estimates of property damage claimed by you, (3) Copies of all written reports of all expert witnesses and treating physicians, {4) A letter from your employer verifying your wages, if self- employed a statement showing the calculation of your claimed lost income: HEREBY CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, THAT THE ATTACHED: STATEMENTS, BILLS, REPORTS AND DOCUMENTS ARE THE ONLY ONIS KNOWNTO ME TO BE.IN EXISTENCE AT THIS TIME. t AM AWARE THAT IF ANY STATEMNT MADE HEREIN IS WILFULLY FALSE OR FRAUDULENT, THAT | WILL BE SUBJECT TO PUNISHMNENT PROVIDED BY. LAW. paren: 2/99 ial) Claimant or filling clainy on behalf of claimant CLE, RacHa tet. ATTY AT RW PLEASE BE ADVISED THAT IN ORDER FOR YOUR CLAIM TO BE CONSIDERED, YOU MUST ALSO COMPLETE AND SIGN THE ATTACHED AUTHORIZATION TO DISCLOSE HEALTH INFORMANTION FORMS AS TO EACH MEDICAL PROVIDER EMNTIONED IN THIS CLAIM FORM. - bomen ESX-L-004552-22 02/09/2023 6:12:21 PM Pg15of18 Trans ID: LCV2023501728 POLICE DEPARTMENT _ PROPERTY EVIDENCE oN RECEIPT NEWARK, NJ [FOUN OR RECOVERED By (2) SECTOR conan ay DISTRICT ha RAL COMPLAINT NO | 599 UNIT ti Tow 13h SOUTH STH 22031005 TIME 249 DATE FOUN OR i 91 DEWEY ST, NEWARK NJ 07112 a - Jul 15, 2022 17:00 | eyonnen Stee “| {6 ADDRESS ANG 21P COD: 13) TELEPHONE NO “RICKETTS, RONALD G 187 DEWEY ST, NEWARKNJ 07112-1360 a BRIEF EXPLAIN\T OM OF FINUINGS AN RECOVERY ime FOLLOWING CURRENCY IS PERSONAL PROPERTY RECOVERED FROM A SEARCH WARRANT. ‘TWELVE (12) $100's = $1,200.00... — 712) PRISONER (A) CANIMAER “AGE DAIL OF ARREST (13) ENVELOPE CONTROL HURABER 1 — - |__ “panes CHARGES: t PRISONER (8) CANUMSER AGE DATE OF ARREST 7 NVELOPE CONTROL KUMBER peer ADDRESS CHARGES PRISONER(C) CA NUMBER AGE DATE OF ARREST (73) ENVELOPE CONTROL NUMBER ADORESS: CHARGES PRISONER (0) CAHUMBER AGE DATE OF ARREST (15) ENVELOPE CONTROL NUMBER ‘ADDRESS CHARGES: 14 116) on (18) ITEM oT EVIDENCE SOURCE ARTICLE DESCRIPTION ESTIMATED CASH VALUE 12 TWELVE (12) $100'S = $1,200.00 1a FOURTEEN (14) $1'S =$14.00 TOTAL = $1,214.00 a - ¥°9) NARG FIELD TEST BY COMMANL COCAINE RESULTS HEROIN RESULIS (20) PROPERTY (Clarrest-evinence (Jrouno Cloecevenis ([]stoven [Z)PERSONAL PROPERTY CF PRISONER (21) CURRENCY JEWELRY FURS GLOTINNG BISCE) LANEOUS TOTAL TOTAL NO OF PROP 28 EVIO RECEIPTS aya OF a RECEIPTS (23) OFFICE! COMMAND, (24} SUPERIOR RECEIVING REC ‘COMMAND PO FORT! 11005 STH LT REYES, JOEL 90% (25) PROPERTY LOCATION BELOW FOR PROPERTY ROOM USE ONLY - RECORD OF PROPERTY MOVEMENT (26) PROSECUTOR'S RELEASE SeNr (28) item RECEIVED PRIN PHOTO TAKEN BY DATE OK TO RELCASE ITEMS BY ME, ‘SIGNATURE 7) sicuafl RE TO Awe t SEALED iF angen Te & orrcen a we o's |, ENVELOPE NUMBER / COMMENTS [ome PROP. oATe NO. FESINGBY oF Busine 4 Ras ld Brwerrs BUT pe he _ tL | HEREBY ACKNOWLEDGE RECEIVING FROM THE POLICE DEPARTMENT THE PROPERTY LISTED BELOW pe I 0d AQORESS: KE LL 4 ITE NO ate Re AALG Danae Mo ESX-L-004552-22 02/09/2023 6:12:21 PM Pg16of18 Trans ID: LCV2023501728 at abe 135 40 WOvERNG SHOMNULST! 571.40 398 — - oy = aa 6 - ATY ETS dG $39%4 10 BIaNNN 2 Anat 2 Ad ORGaH or Qe: tt ZeOe/vt/e TROOTN ‘YATIS LOS Tv06 i Ag OaLsHUBA os AG O3HONCY ABH$e AD GIVI ce qua 9¢ SNAAISSTID 9 OMMAOYUAY HOSIAYIENS 5: BNO] NOWIisISSYIOIS 9S ‘S1LOONY TInGY ON) saenmarl_ owl ainene(_] NOUVOIISSYIO Be {$3409 HO ONvANIOD WIYN S.9391440 6 SS3NGQY S.YBNMO & sooteozza wTLO tts 9 QTNOY ' SLEDIOTY BAUNAN ANY IUMIOD TUNED 2b ON LonBLSIO Le yoigas 0. U3GVINN IHOHYIIL Z BUPIN SBNERO ATSIHSA GAMOL 35I70d MYVMBN ESX-L-004552-22 02/09/2023 6:12:21PM Pg17of18 Trans ID: LCV2023501728 . DENTE BROS. Towing, Inc. My a3 Ee 27 Raymond Bivd. (973) 344-3100 Newark, NJ 07105 (973) 465-1062 DENTStE BROT HERS TORING RAYALING WEYD i wisi ie0 OT/18/ 204. l2.4l Sale RONALD RUCKETES S 331452 Trans #: 39 hatet #9 L yeni CARD Eutry Type: 20]