On January 24, 2023 a
Motion-Secondary
was filed
involving a dispute between
Julia Mcgowan,
Mildred Rockhill,
Nancy Solomon,
and
Abc Corporations 1-5,
Amy Abordelon,
Crystal Lopez,
John Does 1-5,
John Hoffman,
Kevin Carvajal,
U.S. Outlet Stores,
U.S. Polo Assn.,
for Law Against Discrimination (Lad) Cases
in the District Court of Monmouth County.
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MON-L-000214-23 06/29/2023 12:43:48 PM Pg 1 of 1 Trans ID: LCV20231973505
MATTHEW P. GALLO
MGALLO@GRSM.COM
DIRECT DIAL: (973) 549-2531
Admitted In: NJ, NY and PA
ATTORNEYS AT LAW
18 COLUMBIA TURNPIKE, SUITE 220
FLORHAM PARK, NJ 07932
PHONE: (973) 549-2500
FAX: (973) 377-1911
WWW .GRSM.COM
June 29, 2023
VIA ECOURTS
Hon. Mara Zazzali-Hogan, J.S.C.
Superior Court of New Jersey
Monmouth County Superior Court
71 Monument Street
Freehold, New Jersey 07728
Re: Julia McGowan et al. v. U.S. Outlet Stores Tinton Falls, LLC
Docket No.: MON-L-214-23
Dear Judge Zazzali-Hogan:
This firm represents Defendants U.S. Outlet Stores Tinton Falls LLC, U.S. Polo Assn.,
Kevin Carvajal, John Hoffman, Amy Abordelon, and Crystal Lopez (collectively, “Defendants”)
in connection with the above-referenced matter. Defendants are in receipt of Plaintiffs’ Motion
to Compel responses to their First Set of Interrogatories and Request for Production of Documents
dated January 24, 2023.
Initially, although Plaintiff served Request for Production of Documents and First Set of
Interrogatories along with the filed Complaint (also dated January 24, 2023), the undersigned was
not retained by Defendants until February 21, 2023 and an Answer was not filed until April 24,
2023. Moreover, Plaintiff has yet to respond to Defendants’ Request for Documents and First Set
of Interrogatories which are due on July 5 and July 29, respectively. As such, this case remains in
the very early stages of discovery.
Notwithstanding, Defendants have finalized their written responses and objections to
Defendants’ First Set of Interrogatories and are waiting on signed Certifications from the four
individual defendants. Due to vacations and professional commitments, the undersigned has been
unable to connect with a few of the individuals defendants. It is Defendants’ intent to serve written
certified responses prior to the July 7 motion return date (and certainly prior to any Court Order).
As to Defendants’ document production and written responses to Plaintiff’s Request for
Documents, Defendants served responses and bates-stamped documents DEFS1-320 earlier today.
We thank Your Honor for her attention to this matter and consideration herein.
Respectfully submitted,
GORDON REES SCULLY MANSUKHANI, LLP
s/ Matthew P. Gallo
MATTHEW P. GALLO, ESQ.
Preview
MON-L-000214-23 06/29/2023 12:43:48 PM Pg 1 of 1 Trans ID: LCV20231973505 MATTHEW P. GALLO MGALLO@GRSM.COM DIRECT DIAL: (973) 549-2531 Admitted In: NJ, NY and PA ATTORNEYS AT LAW 18 COLUMBIA TURNPIKE, SUITE 220 FLORHAM PARK, NJ 07932 PHONE: (973) 549-2500 FAX: (973) 377-1911 WWW .GRSM.COM June 29, 2023 VIA ECOURTS Hon. Mara Zazzali-Hogan, J.S.C. Superior Court of New Jersey Monmouth County Superior Court 71 Monument Street Freehold, New Jersey 07728 Re: Julia McGowan et al. v. U.S. Outlet Stores Tinton Falls, LLC Docket No.: MON-L-214-23 Dear Judge Zazzali-Hogan: This firm represents Defendants U.S. Outlet Stores Tinton Falls LLC, U.S. Polo Assn., Kevin Carvajal, John Hoffman, Amy Abordelon, and Crystal Lopez (collectively, “Defendants”) in connection with the above-referenced matter. Defendants are in receipt of Plaintiffs’ Motion to Compel responses to their First Set of Interrogatories and Request for Production of Documents dated January 24, 2023. Initially, although Plaintiff served Request for Production of Documents and First Set of Interrogatories along with the filed Complaint (also dated January 24, 2023), the undersigned was not retained by Defendants until February 21, 2023 and an Answer was not filed until April 24, 2023. Moreover, Plaintiff has yet to respond to Defendants’ Request for Documents and First Set of Interrogatories which are due on July 5 and July 29, respectively. As such, this case remains in the very early stages of discovery. Notwithstanding, Defendants have finalized their written responses and objections to Defendants’ First Set of Interrogatories and are waiting on signed Certifications from the four individual defendants. Due to vacations and professional commitments, the undersigned has been unable to connect with a few of the individuals defendants. It is Defendants’ intent to serve written certified responses prior to the July 7 motion return date (and certainly prior to any Court Order). As to Defendants’ document production and written responses to Plaintiff’s Request for Documents, Defendants served responses and bates-stamped documents DEFS1-320 earlier today. We thank Your Honor for her attention to this matter and consideration herein. Respectfully submitted, GORDON REES SCULLY MANSUKHANI, LLP s/ Matthew P. Gallo MATTHEW P. GALLO, ESQ.