Preview
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof2 Trans ID: LCV20233150504
The Law Offices of
PATRICK G. PATEL
580 Newark Avenue
Jersey City, New Jersey 07306
(201) 656- 6504 FAX: (201) 656-4760;
Attorney for the Plaintiff Kevin Cannon
SUPERIOR COURT OF NEW JERSEY
KEVIN CANNON LAW DIVISION ESSEX COUNTY
Plaintiff,
DOCKET NO: ESX-L-2948-22
VS.
CIVIL ACTION
STARBUCKS, RAMSEY SPRING LLC AND JOHN
NOTICE OF MOTION TO EXTEND DISCOVERY
DOE (1 THROUGH X) JANE DOE (1 THROUGH X)
(A PERSON, PERSONS OR ENTITY WHOSE
IDENTITY IS NOT KNOWN) JOINTLY,
SEVERALLY, OR IN THE ALTERNATIVE
Defendants,
TO: ATTN: CIVIL CASE MANAGEMENT
Essex County Superior Court
50 West Market Street Room 131
Newark, New Jersey 07102
VIA EMAIL: NJE-FILE@THEHARTFORD.COM
ATTN: MARY BETH EHALT, ESQ.
Law Offices of Linda S. Bauman
67 East Park Place, Suite 201
Morristown, NJ 07960
Counsel for Defendant Ramsey Spring LLC
VIA EMAIL: JHABRAMSON@PBNLAW.COM
ATTN: JOSHUA H. ABRAMSON, ESQ.
Porzio Bromberg & Newman
100 Southgate Parkway
Morristown, NJ 07962
Counsel for Defendant Starbucks
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504
RETURNABLE: Friday November 03, 2023 at 9:00 a.m. or as soon thereafter as counsel shall be
heard.
PLACE: Essex County Superior Court 50 West Market Street Room 131 Newark,
New Jersey 07102.
RELIEF SOUGHT: For the discovery to be extended for a period of 90 days, through
Thursday, March 14, 2024.
ORAL ARGUMENT: ORAL ARGUMENT IS WAIVED UNLESS OPPOSITION IS FILED.
DATED: October 18, 2023 By:
JOSEPH A SICLARI, ESQ.
New Jersey Attorney ID No.: 042602011
Attorney for the Plaintiff(s)
Kevin Cannon
ESX-L-002948-22 10/18/2023 3:24:01 PM Pglof3 Trans ID: LCV20233150504
The Law Offices of
PATRICK G. PATEL
580 Newark Avenue
Jersey City, New Jersey 07306
(201) 656- 6504 FAX: (201) 656-4760;
Attorney for the Plaintiff Kevin Cannon
SUPERIOR COURT OF NEW JERSEY
KEVIN CANNON LAW DIVISION ESSEX COUNTY
Plaintiff, DOCKET NO: ESX-L-2948-22
vs. CIVIL ACTION
STARBUCKS, RAMSEY SPRING LLC AND JOHN CERTIFICATION IN SUPPORT OF
DOE (1 THROUGH X) JANE DOE (1 THROUGH X) PLAINTIFF'S MOTION TO EXTEND
(A PERSON, PERSONS OR ENTITY WHOSE DISCOVERY
IDENTITY IS NOT KNOWN) JOINTLY,
SEVERALLY, OR IN THE ALTERNATIVE
Defendants,
I, JOSEPH A. SICLARI, ESQ., of full age and being duly sworn hereby certifies as follows:
1 Iam an attorney with the Law Office of Patrick G. Patel, attorneys for the Plaintiff, and as
such am fully familiar with the procedural history and facts of this case.
The supporting facts of this application are as follows:
The Plaintiff was injured while involved in an accident on July 23, 2021, involving
defendant(s), Ramsey Spring, LLC. A civil suit was filed in the Hudson County Superior
Court on May 19, 2022, which bears docket number ESX-L-2948-22. (ExhibitA)
The original discovery end date in this matter was July 18, 2023 and was extended by
stipulation on May 17, 2023. (Exhibit B)
The first Motion to Extend Discovery was filed on August 23, 2023 and the Order granted
on September 08, 2023. (Exhibit C)
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504
6. Plaintiff's counsel has obtained a forensic economist to provide a report opining on the
aforementioned, and is awaiting the receipt of same.
Additionally; Plaintiff has an open Workers’ Compensation claim in which we are awaiting
a final subrogation lien.
This motion is made pursuant to Rule 4:24-1(c) and 4:21-2, wherein good cause must be
shown, and the motion must be returnable prior to the discovery end date. This motion will
be returnable prior to the current expiration of discovery. Under Ponden, the Court
discusses that extensions of discovery, especially for the purposes of obtaining expert
reports, should be liberally granted. Ponden v. Ponden, 374 N.J.Super. 1, 9-11 (App. Div.
2004).
Furthermore, pursuant to Rule 4:24-1(c), I have personally called my adversary, who has
graciously consented to the extension of discovery in this matter.
10. The Plaintiff requests and proposes a ninety-day (90) extension of discovery, until March
14, 2024 with a timeline as follows:
11 Plaintiff must propound expert reports by January 14, 2024.
12. Defendants must propound expert reports by February 14, 2024.
13 All depositions must be completed by the discovery end date.
14, For the foregoing reasons, the Plaintiff respectfully requests the Court to grant the Plaintiff's
request for an extension of discovery for 90 days, bringing the discovery end date to March
14, 2024.
ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504
I CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, SHOULD ANY OF THE
FOREGOING STATEMENTS BE FOUND TO BE WILLFULLY FALSE, I AM SUBJECT TO PUNISHMENT FOR
CONTEMPT OF COURT.
DATED: October 18, 2023 By:
JOSEPH A. SICLARI, ESQ.
New Jersey Attorney ID No. 042602011
Attorney for the Plaintiff
Kevin Cannon
ESX-L-002948-22 10/18/2023 3:24:01 PM Pg lof2 Trans ID: LCV20233150504
The Law Offices of
PATRICK G. PATEL
580 Newark Avenuc
Jersey City, New Jersey 07306
(201) 6. 6504 FAX: (201) 656-4760;
Attorney for the Plaintiff Kevin Cannon
SUPERIOR COURT OF NEW JERSEY
KEVIN CANNON LAW DIVISION ESSEX COUNTY
Plaintiff,
DOCKET NO: ESX-L-2948-22
vs.
CIVIL ACTION
STARBUCKS, RAMSEY SPRING LLC AND JOHN
PROOF OF SERVIC.
DOE (1 THROUGH X) JANE DOE (1 THROUGH X)
(A PERSON, PERSONS OR ENTITY WHOSE
IDENTITY IS NOT KNOWN) JOINTLY,
SEVERALLY, OR IN THE ALTERNATIVE
Defendants,
The original of the within Notice of Motion has been filed with the Clerk of the Essex County
Superior Court,
Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102.
JOSEPHA. SiCLARI, ESQ.
Attorney for the Plaintiff(s)
PROOF OF SERVICE: On October 18, 2023, I the undersigned mailed electronically to:
ATTN: MARY BETH EHALT, ESQ.
Law Offices of Linda S. Bauman
67 East Park Place, Suite 201
Morristown, NJ 07960
Counsel for Defendant Ramsey Spring LLC
ATTN: JOSHUA H. ABRAMSON, ESQ.
Porzio Bromberg & Newman
100 Southgate Parkway
Morristown, NJ 07962
Counsel for Defendant Starbucks
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504
by Electronic Mail the following:
Notice of Motion to Extend Discovery, Affidavit or Certification and all attachments
in support of this motion and Order.
1 CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, SHOULD ANY OF THE
FOREGOING STATEMENTS BE FOUND TO BE WILLFULLY FALSE, I AM SUBJECT TO PUNISHMENT FOR
CONTEMPT OF COURT.
DATED: October 18, 2023
JOSEPH A. SICLARI, ESQ.
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof3 Trans ID: LCV20233150504
EXHIBITA
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504
Case Summary
Case Number: ESX L-002948-22
Case Caption: Cannon Kevin Vs Ramsey Spring Lc
Court: Civil Part Venue: Essex Case Initiation Date: 05/19/2022
Case Type: Personal Injury Case Status: Active Jury Demand: 6 Jurors
Case Track: 2 Judge: Russell J Passamano Team: 3
Original Discovery End Date: 07/18/2023 Current Discovery End Date: 12/15/2023 # of DED Extensions: 2
Original Arbitration Date: Current Arbitration Date: # of Arb Adjournments: 0
Original Trial Date: Current Trial Date: # of Trial Date Adjournments: 0
Disposition Date: Case Disposition: Open Statewide Lien:
Plaintiffs
Kevin Cannon
Party Description: Individual Attorney Name: Patrick G Patel
Address Line 1: Address Line 2: Attorney Bar ID: 000071985
City: Zip: 00000 Phone:
State: NJ
Attorney Email: PGPLAWNJ@GMAIL.COM
Defendants
Ramsey Spring Lic
Party Description: Business Attorney Name: Richard Evan Barber
Address Line 1: 555 Miller Court Address Line 2: Attorney Bar ID: 039632004
City: Wyckoff State: NJ Zip: 07481 Phone:
Attorney Email: RICHARD.BARBER@HBANDGLAW.COM
John Doe
Party Description: Fictitious Attorney Name:
Address Line 1: Address Line 2: Attorney Bar ID:
City: State: NJ Zip: 00000 Phone:
Attorney Email:
Starbucks
Party Description: Business Attorney Name: Joshua Abramson
Address Line 1: 561 Franklin Turnpike Address Line 2: Attorney Bar ID: 029941999
Zip: 07446 Phone:
City: Ramsey State: NJ
Attorney Email: JHABRAMSON@PBNLAW.COM
Case Proceeding
Created Actual Court Judge Name Proceeding Description Motion Type Proceeding Motion Status:
Date Time Room
08/05/2022 09:00 REMO RUSSELL J MOTION HEARING SGgsttrre SERVICE COMPLETED cM
PASSAMANO.
MOTION TO STRIKE
09:00 REMO RUSSELL J MOTION HEARING ANSWER OR MOTION RSCHED
02/03/2023 PASSAMANO TO STRI
SUPPRESS ANSWER
MOTION TO STRIKE
a RUSSELL J MOTION HEARING ANSWER OR MOTION CANCEL cc
02/17/2023 09:00 PASSAMANO TO STRIKE OR
SUPPRESS ANSWER
RENO RUSSELL J MOTION TO EXTEND COMPLETED
09/08/2023 09:00 PASSAMANO MOTION HEARING DISCOVERY cM
Case Actions
Filed Date |Docket Text Transaction ID Entry Date
08/08/2022 PROOF OF SERVICE submitted by PATEL, PATRICK, G of PATRICK G. PATEL on L.cv20222870208 08/08/2022
behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS:
‘Complaint with Jury Demand for ESX-L-002948-22 submitted by PATEL, PATRICK
05/19/2022 Parmiek G, PATEL on behalf of KEVI IN CANNON against RAMSEY SPRING LLC, JOHN L.cv20221952009 05/19/2022
ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504
05/20/2022 TRACK ASSIGNMENT Notice submitted by Case Management L.CV20221963194 05/20/2022
AMENDED COMPLAINT submitted by PATEL, PATRICK, G of PATRICK G. PATEL on LCVv20222500443 07/07/2022
07/07/2022 behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS
07/11/2022
AFFIDAVIT OF SERVICE submitted by PATEL, PATRICK, G of PATRICK G. PATEL on LCV20222542010 07/11/2022
behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS:
MOTION TO SUBSTITUTE SERVICE submitted by PATEL, PATRICK, G of PATRICK G.
07/12/2022 PATEL on behalfof KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, L.v20222556123 07/12/2022
STARBUCKS
The motion filed on 07/12/2022 will be decided on 08/05/2022. Do not come to the
07/12/2022 requested. The court's decision will be LCV20222560337 07/12/2022
courthouse because no oral argument
provided to you. Re: MOTION TO SUI BoTTUTE SI SERVICE [LCV2022255612:
08/05/2022
ORDER SUBSTITUTE SERVICE-Granted by Judge PASSAMANO, RUSSELL, J re: Lcv20222844059 18/05/2022
MOTION TO SUBSTITUTE SERVICE [LCV20222556 123]
‘STIPULATION TO EXTEND TIME FOR ANSWER submitted by ABRAMSON, JOSHUA of
08/12/2022 Peninot BROMBERG & NEWMAN PC on behalf of STARBUCKS against KEVIN LCV20222931105 08/12/2022
‘STIPULATION TO EXTEND TIME FOR ANSWER submitted by ABRAMSON, JOSHUA of
09/02/2022 PORTS ERE RBERC & NEWMAN PC on behalf of STARBUCKS against KEVI LCV20223165129 09/02/2022
Answer WiJury Demand submitted by EHALT, MARY, BETH of HARTFORD
09/21/2022 INSURANCE on behalf of RAMSEY SPRING LLC against KEVIN CANNON, JOHN DOE, Lv20223396306 09/21/2022
STARBUCKS
‘Answer W/CrossClaim W/Jury Demand submitted by ABRAMSON, JOSHUA of PORZIO
09/28/2022 BROMBERG & NEWMAN PC on behalf of STARBUCKS against KEVIN CANNON, Lov20223483925 09/28/2022
RAMSEY SPRING LLC
‘Answer W/CrossClaim WiJury Demand submitted by EHALT, MARY, BETH of
10/12/2022 HARTFORD INSURANCE on behalf of RAMSEY SPRING LLC against KEVIN CANNON, Lv20223617415 10/12/2022
JOHN DOE, STARBUCKS
MOTION TO STRIKE ANSWER OR MOTION TO STRIKE OR SUPPRESS ANSWER
01/18/2023 submitted by PATEL, PATRICK, G of PATRICK G. PATEL on behalf of KEVIN CANNON LCV2023300823 01/18/2023
against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS “LINKED FILING*
The motion filed on 01/18/2023 will be decided on 02/03/2023. Do not come to the
courthouse because no oral ai ument has been requested. The urt's decision will be
01/19/2023 rf
rovided to u. Re: MOTION 'O STRIKE ANSWER OR MOTION TO STRIKE OR
jUPPRESS ANSWER [LCV2023300823}
LCV2023310398 04/19/2023
SUBSTITUTE ATTORNEY submitted by BARBER, RICHARD, EVAN of HAWORTH
01/19/2023 eT & GERSTMAN LLC on behalf of RAMSEY SPRING LLC against KEVIN LCv2023314899 01/19/2023
ADJOURNMENT REQUEST (MOTION) submitted by BARBER, RICHARD, EVAN of
01/26/2023 HAWORTH BARBER & GERSTMAN LLC on behalf of RAMSEY SPRING LLC against Lv2023373932 01/26/2023
KEVIN CANNON “LINKED FILING”
The motion filed on 01/18/2023 was rescheduled to 02/17/2023. Do not come to the
ee
courthouse because no oral argument has been requested. The court's decision will be Lcv2023374270 01/26/2023
01/26/2023 to you. Re: MOTION ‘O STRIKE ANSWER OR MOTION TO STRIKE OR
SSS ANSWER [LCV2023300823]
WITHDRAWAL OF MOTION submitted PATEL, PATRICK, G of PATRICK G. PATEL LCV2023567877 02/16/2023
02/16/2023 on behalf of KEVIN CANNON against ISEY SPRING LLC *LINKED FILING™
Motion Result: Withdrawn on 02/16/2023 re: MOTION TO STRIKE ANSWER OR MOTION LCV2023568617 02/16/2023
02/16/2023 TO STRIKE OR SUPPRESS ANSWER [LCV202330082.
NOTICE OF APPEARANCE (NOT THE FIRST PAPER) submitted by TADROS, JOELLE,
02/16/2023 N of HAWORTH BARBER & GERSTMAN LLC on behalf of RAMSEY SPRING LLC Lv2023585419 02/16/2023
against KEVIN CANNON
05/08/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management Lv20231475988 05/08/2023
DISCOVERY EXTENSION STIPULATION submitted by PATEL, PATRICK, G of PATRICK
05/17/2023, . PATEL on behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, LCV20231565784 05/17/2023
STARBUCKS
05/19/2023 TRACK ASSIGNMENT Notice submitted by Case Management LCV20231582046 05/19/2023
07/10/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management LCV20232037562 07/10/2023
MOTION TO EXTEND DISCOVERY submitted by PATEL, PATRICK, G of PATRICK G.
08/23/2023 PATEL on behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, LCv20232411050 08/23/2023,
STARBU!
The motion filed on 08/23/2023 will be decided on 09/08/2023. Do not come to the
ft i e court's decision will be L.CVv20232419602 08/23/2023
08/23/2023
fe
courthouse because no oral at rgument has
wy
provided to you. Re: MOTION 'O EXTEND DISC OvERY { iLCV202324 11050}
09/08/2023
ORDER EXTEND DISCOVERY-Granted by Judge PASSAMANO, RUSSELL, J re: LCV20232684611 09/12/2023
MOTION TO EXTEND DISCOVERY [LCV2023241 1050]
10/09/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management Lv20233074757 10/09/2023
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof2 Trans ID: LCV20233150504
EXHIBIT B
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504
ESX-L-002948-22 05/17/2023 12:02:27 PM Pg1of1 Trans ID: LCV20231565784
‘The Law Officesof
at l Patrick G. Patel & Associates
Other off
580 Newark Avenuc 14 Ws or
Jersey City, New Jersey 07306 New York, NY 10005 _
Phone: (201) 656-6504 Fax: (201) 656-4760 Joseph A.
Admitted to PA and NI Bar:
PGPlawNJ@gmail.com
May 17, 2023
VIA ELECTRONIC FILING TO:
ATTN: CIVIL CASE MANAGEMENT
Essex County Superior Court
50 West Market Street Room 131
Newark, New Jersey 07102
RE: RE: CANNON v. RAMSEY SPRING, et als.
Docket No.: ESX-L-2948-22
Dear Sir/Madam:
In connection with the above-referenced matter, please be advised that my office represents
the Plaintiff in this lawsuit. The purpose for this letter is to respectfully request a sixty (60) day
extension of discovery in this matter by consent pursuant to Rule 4:24-1(c). The current discovery
end date in this case is July 18, 2023, and has not been extended by either party to date. I have
personally spoken with my adversaries, who have graciously consented to the extension.
Should you have any questions, please do not hesitate to contact my office.
Thank you for your kind attention and courtesies in this matter.
Very Truly Yours,
Is! Patnich G. Patet
PATRICK G. PATEL, ESQ.
PGP/dl
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof3 Trans ID: LCV20233150504
EXHIBIT C
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504
ESX-L-002948-22 09/08/2023 Pi 1 of2_ Trans ID: LCV20232684611
a
mer CUueutOnee YOIZOZUZS 1 19S14Y M Pg 1ot2 Trans ID: LCV20232411050
hea
econ
The Law Offices of
PATRICK G. PATEL
580 Newark Avenuc
Jersey City, New Jersey 07306
(201) 656- 6504 FAX: (201) 656-4760;
Attorney for the Plaintiff Kevin Cannon
—
SUPERIOR COURT OF NEW JERSEY
KEVIN CANNON LAW DIVISION ESSEX COUNTY
Plaintiff,
vs. DOCKET NO: ESX-L-2948-2:
CIVIL ACTION
STARBUCKS, RAMSEY SPRING, LLC, AND JOHN
DOE (1 THROUGH X) JANE DOE (1 THROUGH X)
(A PERSON, PERSONS OR ENTITY WHOSE ORDER
Nev ven: jalysyoe
IDENTITY IS NOT KNOWN) JOINTLY,
SEVERALLY, OR IN THE ALTERNATIVE
Defendants,
THIS MATTER having been open to the Court by JOSEPH A. SICLARI, ESQ.,
attorney for the Plaintiff, for an Order to Extend Time for Discovery, and the Court having considered the
matter and for good cause shown;
IT IS on this, Xth _day of Se bea ber ras,
ORDERED that discovery be and hereby is extended Ninety (90) days to December
15, 2023, and it is further;
ORDERED that the Plaintiff is to supply any and all expert narrative reports as to
liability or damages on or before October 15, 2023; and it is further;
ORDERED that the Defendant is to provide any and all responsive expert reports on
liability and/or damages on or before November 15, 2023; and it is further;
ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504
P 2of 2. Trans ID: LCV20232684611
ur
ESX-L-002948-22 09/08/2023
eroue tures YOZaIZULS 10s:4¥ R MPG Zor Irans ID: LCV20232411050
ORDERED that any and all expert depositions are to be completed on or before
December 15, 2023; and it is further;
ORDERED that any and all discovery is to be completed in this matter on or before
December 15, 2023 oritis-deemed-te-be-waived-by the-pasties; and it is further;
ORDERED that a copy of this Order shall be served upon all parties of the records
within 7 days of receipt of the Order.
1
\ Wir essa? ) USC.
[ ] OPPOSED
x UNOPPOSED
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof1l Trans ID: LCV20233150504
The Law Offices of
Patrick G. Patel & Associates
Reply to: Phone: 201-656-6504
580 Newark Avenue Fax: 201-656-4760.
Jersey City, New Jersey 07306
Other office: PGPLawNJ@gmail.com
14 Wall Street, 20th Floor 20 UnjuryLaw.com
New York, New York 10005
Joseph A. Siclari, Esq.*, Partner WilliamJ. Scherman, Esq., Of Counsel
Admitted to NJ and PA Bars Admitted to NJ Bar
Daniela Pepe, Esq., Associate Michael N. David, Esq., Of Counsel
Admitted to NJ Bar Admitted to NJ and NY Bars.
Certified by the Supreme Court of New Jersey
as a Civil Trial Attorney
October 18, 2023
VIA ELECTRONIC FILING:
ATIN: CIVIL DOCUMENTS TEAM
Essex County Superior Court
50 West Market Street Room 131
Newark, New Jersey 07102
RE: KEVIN CANNON V. RAMSEY SPRING LLC, ET ALS
Docket No.: ESX-L-002948-22
Dear Sir/Madam:
In connection with the above-referenced matter, enclosed please find the following
documents prepared on behalf of the Plaintiff in connection with the above referenced matter:
1 Notice of Motion to Extend Discovery;
2. Certificate ;
3 Proof of Mailing;
4 Order;
Thank you for your anticipated courtesies and cooperation in this matter.
Very Truly Yours,
JOSEPH A. SICLARI, ESQ.
JAS/d1
ESX-L-002948-22 10/18/2023 3:24:01 PM Pglof2 Trans ID: LCV20233150504
The Law Offices of
PATRICK G. PATEL
580 Newark Avenue
Jersey C New Jersey 07306
(201) 504 FAX: (201) 656-4760;
Attorney for the Plaintiff Kevin Cannon
SUPERIOR COURT OF NEW JERSEY
KEVIN CANNON LAW DIVISION ESSEX COUNTY
Plaintiff,
vs.
DOCKET NO: ESX-L-2948-22
CIVIL ACTION
STARBUCKS, RAMSEY SPRING, LLC, AND JOHN
DOE (1 THROUGH X) JANE DOE (1 THROUGH X) ORDER
(A PERSON, PERSONS OR ENTITY WHOSE
IDENTITY IS NOT KNOWN) JOINTLY,
SEVERALLY, OR IN THE ALTERNATIVE
Defendants,
THIS MATTER having been open to the Court by JOSEPH A. SICLARI, ESQ.,
attorney for the Plaintiff, for an Order to Extend Time for Discovery, and the Court having considered the
matter and for good cause shown;
IT IS on this, day of , 2023,
ORDERED that discovery be and hereby is extended Ninety (90) days to March 14,
2024, and it is further;
ORDERED that the Plaintiff is to supply any and all expert narrative reports as to
liability or damages on or before January 14, 2024; and it is further;
ORDERED that the Defendant is to provide any and all responsive expert reports on
liability and/or damages on or before February 14, 2024; and it is further;
ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504
ORDERED that any and all expert depositions are to be completed on or before
March 14, 2024; and it is further;
ORDERED that any and all discovery is to be completed in this matter on or before
March 14, 2024 or it is deemed to be waived by the parties; and it is further;
ORDERED that a copy of this Order shall be served upon all parties of the records
within days of receipt of the Order.
IS.C.
| |] OPPOSED
[| |] UNOPPOSED
Preview
ESX-L-002948-22 10/18/2023 3:24:01PM Pglof2 Trans ID: LCV20233150504 The Law Offices of PATRICK G. PATEL 580 Newark Avenue Jersey City, New Jersey 07306 (201) 656- 6504 FAX: (201) 656-4760; Attorney for the Plaintiff Kevin Cannon SUPERIOR COURT OF NEW JERSEY KEVIN CANNON LAW DIVISION ESSEX COUNTY Plaintiff, DOCKET NO: ESX-L-2948-22 VS. CIVIL ACTION STARBUCKS, RAMSEY SPRING LLC AND JOHN NOTICE OF MOTION TO EXTEND DISCOVERY DOE (1 THROUGH X) JANE DOE (1 THROUGH X) (A PERSON, PERSONS OR ENTITY WHOSE IDENTITY IS NOT KNOWN) JOINTLY, SEVERALLY, OR IN THE ALTERNATIVE Defendants, TO: ATTN: CIVIL CASE MANAGEMENT Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102 VIA EMAIL: NJE-FILE@THEHARTFORD.COM ATTN: MARY BETH EHALT, ESQ. Law Offices of Linda S. Bauman 67 East Park Place, Suite 201 Morristown, NJ 07960 Counsel for Defendant Ramsey Spring LLC VIA EMAIL: JHABRAMSON@PBNLAW.COM ATTN: JOSHUA H. ABRAMSON, ESQ. Porzio Bromberg & Newman 100 Southgate Parkway Morristown, NJ 07962 Counsel for Defendant Starbucks ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504 RETURNABLE: Friday November 03, 2023 at 9:00 a.m. or as soon thereafter as counsel shall be heard. PLACE: Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102. RELIEF SOUGHT: For the discovery to be extended for a period of 90 days, through Thursday, March 14, 2024. ORAL ARGUMENT: ORAL ARGUMENT IS WAIVED UNLESS OPPOSITION IS FILED. DATED: October 18, 2023 By: JOSEPH A SICLARI, ESQ. New Jersey Attorney ID No.: 042602011 Attorney for the Plaintiff(s) Kevin Cannon ESX-L-002948-22 10/18/2023 3:24:01 PM Pglof3 Trans ID: LCV20233150504 The Law Offices of PATRICK G. PATEL 580 Newark Avenue Jersey City, New Jersey 07306 (201) 656- 6504 FAX: (201) 656-4760; Attorney for the Plaintiff Kevin Cannon SUPERIOR COURT OF NEW JERSEY KEVIN CANNON LAW DIVISION ESSEX COUNTY Plaintiff, DOCKET NO: ESX-L-2948-22 vs. CIVIL ACTION STARBUCKS, RAMSEY SPRING LLC AND JOHN CERTIFICATION IN SUPPORT OF DOE (1 THROUGH X) JANE DOE (1 THROUGH X) PLAINTIFF'S MOTION TO EXTEND (A PERSON, PERSONS OR ENTITY WHOSE DISCOVERY IDENTITY IS NOT KNOWN) JOINTLY, SEVERALLY, OR IN THE ALTERNATIVE Defendants, I, JOSEPH A. SICLARI, ESQ., of full age and being duly sworn hereby certifies as follows: 1 Iam an attorney with the Law Office of Patrick G. Patel, attorneys for the Plaintiff, and as such am fully familiar with the procedural history and facts of this case. The supporting facts of this application are as follows: The Plaintiff was injured while involved in an accident on July 23, 2021, involving defendant(s), Ramsey Spring, LLC. A civil suit was filed in the Hudson County Superior Court on May 19, 2022, which bears docket number ESX-L-2948-22. (ExhibitA) The original discovery end date in this matter was July 18, 2023 and was extended by stipulation on May 17, 2023. (Exhibit B) The first Motion to Extend Discovery was filed on August 23, 2023 and the Order granted on September 08, 2023. (Exhibit C) ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504 6. Plaintiff's counsel has obtained a forensic economist to provide a report opining on the aforementioned, and is awaiting the receipt of same. Additionally; Plaintiff has an open Workers’ Compensation claim in which we are awaiting a final subrogation lien. This motion is made pursuant to Rule 4:24-1(c) and 4:21-2, wherein good cause must be shown, and the motion must be returnable prior to the discovery end date. This motion will be returnable prior to the current expiration of discovery. Under Ponden, the Court discusses that extensions of discovery, especially for the purposes of obtaining expert reports, should be liberally granted. Ponden v. Ponden, 374 N.J.Super. 1, 9-11 (App. Div. 2004). Furthermore, pursuant to Rule 4:24-1(c), I have personally called my adversary, who has graciously consented to the extension of discovery in this matter. 10. The Plaintiff requests and proposes a ninety-day (90) extension of discovery, until March 14, 2024 with a timeline as follows: 11 Plaintiff must propound expert reports by January 14, 2024. 12. Defendants must propound expert reports by February 14, 2024. 13 All depositions must be completed by the discovery end date. 14, For the foregoing reasons, the Plaintiff respectfully requests the Court to grant the Plaintiff's request for an extension of discovery for 90 days, bringing the discovery end date to March 14, 2024. ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504 I CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, SHOULD ANY OF THE FOREGOING STATEMENTS BE FOUND TO BE WILLFULLY FALSE, I AM SUBJECT TO PUNISHMENT FOR CONTEMPT OF COURT. DATED: October 18, 2023 By: JOSEPH A. SICLARI, ESQ. New Jersey Attorney ID No. 042602011 Attorney for the Plaintiff Kevin Cannon ESX-L-002948-22 10/18/2023 3:24:01 PM Pg lof2 Trans ID: LCV20233150504 The Law Offices of PATRICK G. PATEL 580 Newark Avenuc Jersey City, New Jersey 07306 (201) 6. 6504 FAX: (201) 656-4760; Attorney for the Plaintiff Kevin Cannon SUPERIOR COURT OF NEW JERSEY KEVIN CANNON LAW DIVISION ESSEX COUNTY Plaintiff, DOCKET NO: ESX-L-2948-22 vs. CIVIL ACTION STARBUCKS, RAMSEY SPRING LLC AND JOHN PROOF OF SERVIC. DOE (1 THROUGH X) JANE DOE (1 THROUGH X) (A PERSON, PERSONS OR ENTITY WHOSE IDENTITY IS NOT KNOWN) JOINTLY, SEVERALLY, OR IN THE ALTERNATIVE Defendants, The original of the within Notice of Motion has been filed with the Clerk of the Essex County Superior Court, Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102. JOSEPHA. SiCLARI, ESQ. Attorney for the Plaintiff(s) PROOF OF SERVICE: On October 18, 2023, I the undersigned mailed electronically to: ATTN: MARY BETH EHALT, ESQ. Law Offices of Linda S. Bauman 67 East Park Place, Suite 201 Morristown, NJ 07960 Counsel for Defendant Ramsey Spring LLC ATTN: JOSHUA H. ABRAMSON, ESQ. Porzio Bromberg & Newman 100 Southgate Parkway Morristown, NJ 07962 Counsel for Defendant Starbucks ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504 by Electronic Mail the following: Notice of Motion to Extend Discovery, Affidavit or Certification and all attachments in support of this motion and Order. 1 CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, SHOULD ANY OF THE FOREGOING STATEMENTS BE FOUND TO BE WILLFULLY FALSE, I AM SUBJECT TO PUNISHMENT FOR CONTEMPT OF COURT. DATED: October 18, 2023 JOSEPH A. SICLARI, ESQ. ESX-L-002948-22 10/18/2023 3:24:01PM Pglof3 Trans ID: LCV20233150504 EXHIBITA ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504 Case Summary Case Number: ESX L-002948-22 Case Caption: Cannon Kevin Vs Ramsey Spring Lc Court: Civil Part Venue: Essex Case Initiation Date: 05/19/2022 Case Type: Personal Injury Case Status: Active Jury Demand: 6 Jurors Case Track: 2 Judge: Russell J Passamano Team: 3 Original Discovery End Date: 07/18/2023 Current Discovery End Date: 12/15/2023 # of DED Extensions: 2 Original Arbitration Date: Current Arbitration Date: # of Arb Adjournments: 0 Original Trial Date: Current Trial Date: # of Trial Date Adjournments: 0 Disposition Date: Case Disposition: Open Statewide Lien: Plaintiffs Kevin Cannon Party Description: Individual Attorney Name: Patrick G Patel Address Line 1: Address Line 2: Attorney Bar ID: 000071985 City: Zip: 00000 Phone: State: NJ Attorney Email: PGPLAWNJ@GMAIL.COM Defendants Ramsey Spring Lic Party Description: Business Attorney Name: Richard Evan Barber Address Line 1: 555 Miller Court Address Line 2: Attorney Bar ID: 039632004 City: Wyckoff State: NJ Zip: 07481 Phone: Attorney Email: RICHARD.BARBER@HBANDGLAW.COM John Doe Party Description: Fictitious Attorney Name: Address Line 1: Address Line 2: Attorney Bar ID: City: State: NJ Zip: 00000 Phone: Attorney Email: Starbucks Party Description: Business Attorney Name: Joshua Abramson Address Line 1: 561 Franklin Turnpike Address Line 2: Attorney Bar ID: 029941999 Zip: 07446 Phone: City: Ramsey State: NJ Attorney Email: JHABRAMSON@PBNLAW.COM Case Proceeding Created Actual Court Judge Name Proceeding Description Motion Type Proceeding Motion Status: Date Time Room 08/05/2022 09:00 REMO RUSSELL J MOTION HEARING SGgsttrre SERVICE COMPLETED cM PASSAMANO. MOTION TO STRIKE 09:00 REMO RUSSELL J MOTION HEARING ANSWER OR MOTION RSCHED 02/03/2023 PASSAMANO TO STRI SUPPRESS ANSWER MOTION TO STRIKE a RUSSELL J MOTION HEARING ANSWER OR MOTION CANCEL cc 02/17/2023 09:00 PASSAMANO TO STRIKE OR SUPPRESS ANSWER RENO RUSSELL J MOTION TO EXTEND COMPLETED 09/08/2023 09:00 PASSAMANO MOTION HEARING DISCOVERY cM Case Actions Filed Date |Docket Text Transaction ID Entry Date 08/08/2022 PROOF OF SERVICE submitted by PATEL, PATRICK, G of PATRICK G. PATEL on L.cv20222870208 08/08/2022 behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS: ‘Complaint with Jury Demand for ESX-L-002948-22 submitted by PATEL, PATRICK 05/19/2022 Parmiek G, PATEL on behalf of KEVI IN CANNON against RAMSEY SPRING LLC, JOHN L.cv20221952009 05/19/2022 ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504 05/20/2022 TRACK ASSIGNMENT Notice submitted by Case Management L.CV20221963194 05/20/2022 AMENDED COMPLAINT submitted by PATEL, PATRICK, G of PATRICK G. PATEL on LCVv20222500443 07/07/2022 07/07/2022 behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS 07/11/2022 AFFIDAVIT OF SERVICE submitted by PATEL, PATRICK, G of PATRICK G. PATEL on LCV20222542010 07/11/2022 behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS: MOTION TO SUBSTITUTE SERVICE submitted by PATEL, PATRICK, G of PATRICK G. 07/12/2022 PATEL on behalfof KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, L.v20222556123 07/12/2022 STARBUCKS The motion filed on 07/12/2022 will be decided on 08/05/2022. Do not come to the 07/12/2022 requested. The court's decision will be LCV20222560337 07/12/2022 courthouse because no oral argument provided to you. Re: MOTION TO SUI BoTTUTE SI SERVICE [LCV2022255612: 08/05/2022 ORDER SUBSTITUTE SERVICE-Granted by Judge PASSAMANO, RUSSELL, J re: Lcv20222844059 18/05/2022 MOTION TO SUBSTITUTE SERVICE [LCV20222556 123] ‘STIPULATION TO EXTEND TIME FOR ANSWER submitted by ABRAMSON, JOSHUA of 08/12/2022 Peninot BROMBERG & NEWMAN PC on behalf of STARBUCKS against KEVIN LCV20222931105 08/12/2022 ‘STIPULATION TO EXTEND TIME FOR ANSWER submitted by ABRAMSON, JOSHUA of 09/02/2022 PORTS ERE RBERC & NEWMAN PC on behalf of STARBUCKS against KEVI LCV20223165129 09/02/2022 Answer WiJury Demand submitted by EHALT, MARY, BETH of HARTFORD 09/21/2022 INSURANCE on behalf of RAMSEY SPRING LLC against KEVIN CANNON, JOHN DOE, Lv20223396306 09/21/2022 STARBUCKS ‘Answer W/CrossClaim W/Jury Demand submitted by ABRAMSON, JOSHUA of PORZIO 09/28/2022 BROMBERG & NEWMAN PC on behalf of STARBUCKS against KEVIN CANNON, Lov20223483925 09/28/2022 RAMSEY SPRING LLC ‘Answer W/CrossClaim WiJury Demand submitted by EHALT, MARY, BETH of 10/12/2022 HARTFORD INSURANCE on behalf of RAMSEY SPRING LLC against KEVIN CANNON, Lv20223617415 10/12/2022 JOHN DOE, STARBUCKS MOTION TO STRIKE ANSWER OR MOTION TO STRIKE OR SUPPRESS ANSWER 01/18/2023 submitted by PATEL, PATRICK, G of PATRICK G. PATEL on behalf of KEVIN CANNON LCV2023300823 01/18/2023 against RAMSEY SPRING LLC, JOHN DOE, STARBUCKS “LINKED FILING* The motion filed on 01/18/2023 will be decided on 02/03/2023. Do not come to the courthouse because no oral ai ument has been requested. The urt's decision will be 01/19/2023 rf rovided to u. Re: MOTION 'O STRIKE ANSWER OR MOTION TO STRIKE OR jUPPRESS ANSWER [LCV2023300823} LCV2023310398 04/19/2023 SUBSTITUTE ATTORNEY submitted by BARBER, RICHARD, EVAN of HAWORTH 01/19/2023 eT & GERSTMAN LLC on behalf of RAMSEY SPRING LLC against KEVIN LCv2023314899 01/19/2023 ADJOURNMENT REQUEST (MOTION) submitted by BARBER, RICHARD, EVAN of 01/26/2023 HAWORTH BARBER & GERSTMAN LLC on behalf of RAMSEY SPRING LLC against Lv2023373932 01/26/2023 KEVIN CANNON “LINKED FILING” The motion filed on 01/18/2023 was rescheduled to 02/17/2023. Do not come to the ee courthouse because no oral argument has been requested. The court's decision will be Lcv2023374270 01/26/2023 01/26/2023 to you. Re: MOTION ‘O STRIKE ANSWER OR MOTION TO STRIKE OR SSS ANSWER [LCV2023300823] WITHDRAWAL OF MOTION submitted PATEL, PATRICK, G of PATRICK G. PATEL LCV2023567877 02/16/2023 02/16/2023 on behalf of KEVIN CANNON against ISEY SPRING LLC *LINKED FILING™ Motion Result: Withdrawn on 02/16/2023 re: MOTION TO STRIKE ANSWER OR MOTION LCV2023568617 02/16/2023 02/16/2023 TO STRIKE OR SUPPRESS ANSWER [LCV202330082. NOTICE OF APPEARANCE (NOT THE FIRST PAPER) submitted by TADROS, JOELLE, 02/16/2023 N of HAWORTH BARBER & GERSTMAN LLC on behalf of RAMSEY SPRING LLC Lv2023585419 02/16/2023 against KEVIN CANNON 05/08/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management Lv20231475988 05/08/2023 DISCOVERY EXTENSION STIPULATION submitted by PATEL, PATRICK, G of PATRICK 05/17/2023, . PATEL on behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, LCV20231565784 05/17/2023 STARBUCKS 05/19/2023 TRACK ASSIGNMENT Notice submitted by Case Management LCV20231582046 05/19/2023 07/10/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management LCV20232037562 07/10/2023 MOTION TO EXTEND DISCOVERY submitted by PATEL, PATRICK, G of PATRICK G. 08/23/2023 PATEL on behalf of KEVIN CANNON against RAMSEY SPRING LLC, JOHN DOE, LCv20232411050 08/23/2023, STARBU! The motion filed on 08/23/2023 will be decided on 09/08/2023. Do not come to the ft i e court's decision will be L.CVv20232419602 08/23/2023 08/23/2023 fe courthouse because no oral at rgument has wy provided to you. Re: MOTION 'O EXTEND DISC OvERY { iLCV202324 11050} 09/08/2023 ORDER EXTEND DISCOVERY-Granted by Judge PASSAMANO, RUSSELL, J re: LCV20232684611 09/12/2023 MOTION TO EXTEND DISCOVERY [LCV2023241 1050] 10/09/2023 DISCOVERY END DATE REMINDER Notice submitted by Case Management Lv20233074757 10/09/2023 ESX-L-002948-22 10/18/2023 3:24:01PM Pglof2 Trans ID: LCV20233150504 EXHIBIT B ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504 ESX-L-002948-22 05/17/2023 12:02:27 PM Pg1of1 Trans ID: LCV20231565784 ‘The Law Officesof at l Patrick G. Patel & Associates Other off 580 Newark Avenuc 14 Ws or Jersey City, New Jersey 07306 New York, NY 10005 _ Phone: (201) 656-6504 Fax: (201) 656-4760 Joseph A. Admitted to PA and NI Bar: PGPlawNJ@gmail.com May 17, 2023 VIA ELECTRONIC FILING TO: ATTN: CIVIL CASE MANAGEMENT Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102 RE: RE: CANNON v. RAMSEY SPRING, et als. Docket No.: ESX-L-2948-22 Dear Sir/Madam: In connection with the above-referenced matter, please be advised that my office represents the Plaintiff in this lawsuit. The purpose for this letter is to respectfully request a sixty (60) day extension of discovery in this matter by consent pursuant to Rule 4:24-1(c). The current discovery end date in this case is July 18, 2023, and has not been extended by either party to date. I have personally spoken with my adversaries, who have graciously consented to the extension. Should you have any questions, please do not hesitate to contact my office. Thank you for your kind attention and courtesies in this matter. Very Truly Yours, Is! Patnich G. Patet PATRICK G. PATEL, ESQ. PGP/dl ESX-L-002948-22 10/18/2023 3:24:01PM Pglof3 Trans ID: LCV20233150504 EXHIBIT C ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of3 Trans ID: LCV20233150504 ESX-L-002948-22 09/08/2023 Pi 1 of2_ Trans ID: LCV20232684611 a mer CUueutOnee YOIZOZUZS 1 19S14Y M Pg 1ot2 Trans ID: LCV20232411050 hea econ The Law Offices of PATRICK G. PATEL 580 Newark Avenuc Jersey City, New Jersey 07306 (201) 656- 6504 FAX: (201) 656-4760; Attorney for the Plaintiff Kevin Cannon — SUPERIOR COURT OF NEW JERSEY KEVIN CANNON LAW DIVISION ESSEX COUNTY Plaintiff, vs. DOCKET NO: ESX-L-2948-2: CIVIL ACTION STARBUCKS, RAMSEY SPRING, LLC, AND JOHN DOE (1 THROUGH X) JANE DOE (1 THROUGH X) (A PERSON, PERSONS OR ENTITY WHOSE ORDER Nev ven: jalysyoe IDENTITY IS NOT KNOWN) JOINTLY, SEVERALLY, OR IN THE ALTERNATIVE Defendants, THIS MATTER having been open to the Court by JOSEPH A. SICLARI, ESQ., attorney for the Plaintiff, for an Order to Extend Time for Discovery, and the Court having considered the matter and for good cause shown; IT IS on this, Xth _day of Se bea ber ras, ORDERED that discovery be and hereby is extended Ninety (90) days to December 15, 2023, and it is further; ORDERED that the Plaintiff is to supply any and all expert narrative reports as to liability or damages on or before October 15, 2023; and it is further; ORDERED that the Defendant is to provide any and all responsive expert reports on liability and/or damages on or before November 15, 2023; and it is further; ESX-L-002948-22 10/18/2023 3:24:01PM Pg3o0f3 Trans ID: LCV20233150504 P 2of 2. Trans ID: LCV20232684611 ur ESX-L-002948-22 09/08/2023 eroue tures YOZaIZULS 10s:4¥ R MPG Zor Irans ID: LCV20232411050 ORDERED that any and all expert depositions are to be completed on or before December 15, 2023; and it is further; ORDERED that any and all discovery is to be completed in this matter on or before December 15, 2023 oritis-deemed-te-be-waived-by the-pasties; and it is further; ORDERED that a copy of this Order shall be served upon all parties of the records within 7 days of receipt of the Order. 1 \ Wir essa? ) USC. [ ] OPPOSED x UNOPPOSED ESX-L-002948-22 10/18/2023 3:24:01PM Pglof1l Trans ID: LCV20233150504 The Law Offices of Patrick G. Patel & Associates Reply to: Phone: 201-656-6504 580 Newark Avenue Fax: 201-656-4760. Jersey City, New Jersey 07306 Other office: PGPLawNJ@gmail.com 14 Wall Street, 20th Floor 20 UnjuryLaw.com New York, New York 10005 Joseph A. Siclari, Esq.*, Partner WilliamJ. Scherman, Esq., Of Counsel Admitted to NJ and PA Bars Admitted to NJ Bar Daniela Pepe, Esq., Associate Michael N. David, Esq., Of Counsel Admitted to NJ Bar Admitted to NJ and NY Bars. Certified by the Supreme Court of New Jersey as a Civil Trial Attorney October 18, 2023 VIA ELECTRONIC FILING: ATIN: CIVIL DOCUMENTS TEAM Essex County Superior Court 50 West Market Street Room 131 Newark, New Jersey 07102 RE: KEVIN CANNON V. RAMSEY SPRING LLC, ET ALS Docket No.: ESX-L-002948-22 Dear Sir/Madam: In connection with the above-referenced matter, enclosed please find the following documents prepared on behalf of the Plaintiff in connection with the above referenced matter: 1 Notice of Motion to Extend Discovery; 2. Certificate ; 3 Proof of Mailing; 4 Order; Thank you for your anticipated courtesies and cooperation in this matter. Very Truly Yours, JOSEPH A. SICLARI, ESQ. JAS/d1 ESX-L-002948-22 10/18/2023 3:24:01 PM Pglof2 Trans ID: LCV20233150504 The Law Offices of PATRICK G. PATEL 580 Newark Avenue Jersey C New Jersey 07306 (201) 504 FAX: (201) 656-4760; Attorney for the Plaintiff Kevin Cannon SUPERIOR COURT OF NEW JERSEY KEVIN CANNON LAW DIVISION ESSEX COUNTY Plaintiff, vs. DOCKET NO: ESX-L-2948-22 CIVIL ACTION STARBUCKS, RAMSEY SPRING, LLC, AND JOHN DOE (1 THROUGH X) JANE DOE (1 THROUGH X) ORDER (A PERSON, PERSONS OR ENTITY WHOSE IDENTITY IS NOT KNOWN) JOINTLY, SEVERALLY, OR IN THE ALTERNATIVE Defendants, THIS MATTER having been open to the Court by JOSEPH A. SICLARI, ESQ., attorney for the Plaintiff, for an Order to Extend Time for Discovery, and the Court having considered the matter and for good cause shown; IT IS on this, day of , 2023, ORDERED that discovery be and hereby is extended Ninety (90) days to March 14, 2024, and it is further; ORDERED that the Plaintiff is to supply any and all expert narrative reports as to liability or damages on or before January 14, 2024; and it is further; ORDERED that the Defendant is to provide any and all responsive expert reports on liability and/or damages on or before February 14, 2024; and it is further; ESX-L-002948-22 10/18/2023 3:24:01PM Pg2of2 Trans ID: LCV20233150504 ORDERED that any and all expert depositions are to be completed on or before March 14, 2024; and it is further; ORDERED that any and all discovery is to be completed in this matter on or before March 14, 2024 or it is deemed to be waived by the parties; and it is further; ORDERED that a copy of this Order shall be served upon all parties of the records within days of receipt of the Order. IS.C. | |] OPPOSED [| |] UNOPPOSED