On June 12, 2020 a
Letter,Correspondence
was filed
involving a dispute between
Charles Gosha,
and
10) Doe Corporations (1-,
10) Doe Partnerships (1-,
Dave Gonzalez,
Jane Does,
John Doe Entities,
John Does,
Joseph A Papa, Iii,
Kemarley Bryan,
National Delivery Systems, Inc,
for Assault And Battery
in the District Court of Camden County.
Preview
CAM-L-002007-20 04/14/2022 7:06:34 PM Pg 1 of 1 Trans ID: LCV20221528270
TIMOTHY P. MULLIN
Member of PA and NJ BAR
tpmullin@zarwin.com
April 14, 2022
VIA ECOURTS ONLY
The Honorable Anthony M. Pugliese
Camden County Hall of Justice
101 South 5th Street, 4th Floor
Camden, NJ 08103-4001
RE: Charles Gosha v. National Delivery Systems
Superior Court of New Jersey -Camden County,
Docket No. CAM-L-2007-20
Our File No. 39246
Dear Judge Pugliese:
Please be advised I represent National Delivery Systems, Inc. Joe Papa, III, Dave
Gonzalez and Kemarley Bryan in the above-captioned matter. Plaintiff has filed a motion to
extend discovery in this matter which is currently returnable before your Honor on April 29,
2022. I write to your Honor to join in plaintiff’s motion to extend discovery and to advise the
court of an additional basis to extend the discovery end date in this matter.
As plaintiff noted in his motion papers, I have had difficulty getting in contact with Mr.
Gonzalez and Mr. Bryan. Despite this, depositions of Mr. Papa and a representative from
National Delivery Systems were scheduled for April 20, 2022. Unfortunately, this past Friday,
my older brother passed away unexpectedly. The memorial services have been scheduled for
April 20, 2022 and thus, I have had to adjourn the depositions. I have provided new dates to
plaintiff’s counsel in an effort to reschedule these depositions.
Given the circumstances, I ask or the court’s indulgence and request that the court grant
plaintiff’s motion to extend discovery in order to complete the necessary discovery in this matter.
Respectfully submitted,
TIMOTHY P. MULLIN
TPM/nfs
cc: Adam J. Fein, Esq. (via eCourts)
309 FELLOWSHIP ROAD SUITE 200 MT. LAUREL, NJ 08054 (856) 810-3454 FAX (856) 810-3494 WWW.ZARWIN.COM
PENNSYLVANIA OFFICE: PHILADELPHIA NEW JERSEY OFFICES: JERSEY CITY MT. LAUREL DELAWARE OFFICE: WILMINGTON
Document Filed Date
April 14, 2022
Case Filing Date
June 12, 2020
Category
Assault And Battery
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CAM-L-002007-20 04/14/2022 7:06:34 PM Pg 1 of 1 Trans ID: LCV20221528270 TIMOTHY P. MULLIN Member of PA and NJ BAR tpmullin@zarwin.com April 14, 2022 VIA ECOURTS ONLY The Honorable Anthony M. Pugliese Camden County Hall of Justice 101 South 5th Street, 4th Floor Camden, NJ 08103-4001 RE: Charles Gosha v. National Delivery Systems Superior Court of New Jersey -Camden County, Docket No. CAM-L-2007-20 Our File No. 39246 Dear Judge Pugliese: Please be advised I represent National Delivery Systems, Inc. Joe Papa, III, Dave Gonzalez and Kemarley Bryan in the above-captioned matter. Plaintiff has filed a motion to extend discovery in this matter which is currently returnable before your Honor on April 29, 2022. I write to your Honor to join in plaintiff’s motion to extend discovery and to advise the court of an additional basis to extend the discovery end date in this matter. As plaintiff noted in his motion papers, I have had difficulty getting in contact with Mr. Gonzalez and Mr. Bryan. Despite this, depositions of Mr. Papa and a representative from National Delivery Systems were scheduled for April 20, 2022. Unfortunately, this past Friday, my older brother passed away unexpectedly. The memorial services have been scheduled for April 20, 2022 and thus, I have had to adjourn the depositions. I have provided new dates to plaintiff’s counsel in an effort to reschedule these depositions. Given the circumstances, I ask or the court’s indulgence and request that the court grant plaintiff’s motion to extend discovery in order to complete the necessary discovery in this matter. Respectfully submitted, TIMOTHY P. MULLIN TPM/nfs cc: Adam J. Fein, Esq. (via eCourts) 309 FELLOWSHIP ROAD SUITE 200 MT. LAUREL, NJ 08054 (856) 810-3454 FAX (856) 810-3494 WWW.ZARWIN.COM PENNSYLVANIA OFFICE: PHILADELPHIA NEW JERSEY OFFICES: JERSEY CITY MT. LAUREL DELAWARE OFFICE: WILMINGTON