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BER-L-004731-23 10/31/2023 4:23:14PM Pglof3 Trans ID: LCV20233259155
Louis M. Gerbino, Esq., Attorney ID No. 196862016
HANNA | PEREZ rc
185 Route 17 South
Paramus, New Jersey 07652
(201) 224-9400, Fax: (201) 224-9401
Attomey for Plaintiff, JEEDALLAH H. DAGHASH
SUPERIOR COURT OF NEW JERSEY
JEEDALLAH H. DAGHASH, LAW DIVISION: BERGEN COUNTY
Plaintiff, DOCKET NO.: BER-L-4731-23
vs.
Civil Action
JUAN GONZALEZ, SUSAN J. JAEGER,
ELIZABETH G. QUIMBY, ADILA Z. REQUEST TO ENTER DEFAULT
MANSOORI, JOSHUA F. HOSINE, DRIVE
NEW JERSEY INSURANCE COMPANY,
JOHN DOES 1-5 (fictitiously named
operators, lessors, lessees, ridesharing entity,
employers, agents, or owners of motor
vehicles), and ABC CORP. 1-5 (fictitiously
named operators, lessors, lessees, tidesharing
entity, employers, agents, or owners of motor
vehicles),
Defendants.
TO THE CLERK OF THE ABOVE NAMED COURT:
PLEASE enter the default of the defendants, ADILA Z. MANSOORI and JUAN
GONZALEZ, for failure to plead or otherwise defend as provided by the Rules of Civil Practice of the
Superior Court or by an Order of this Court. A certification in support of this request is attached.
HANNA | PEREZ PC
Attorneys for Plaintiff
PO Bo
LOUIS M. GERBINO, ESQ.
Dated: October 31, 2023
BER-L-004731-23 10/31/2023 4:23:14PM Pg2of3 Trans ID: LCV20233259155
Louis M. Gerbino, Esq., Attorney ID No. 196862016
HANNA | PEREZ rc
185 Route 17 South
Paramus, New Jetsey 07652
(201) 224-9400, Fax: (201) 224-9401
Attomey for Plaintiff, JEEDALLAH H. DAGHASH
SUPERIOR COURT OF NEW JERSEY
JEEDALLAH H. DAGHASH, LAW DIVISION: BERGEN COUNTY
Plaintiff, DOCKET NO.: BER-L-4731-23
vs.
Civil Action
JUAN GONZALEZ, SUSAN J. JAEGER,
ELIZABETH G. QUIMBY, ADILA Z. CERTIFICATION OF LOUIS M.
MANSOORI, JOSHUA F. HOSINE, DRIVE GERBINO
NEW JERSEY INSURANCE COMPANY,
JOHN DOES 1-5 (fictitiously named
operators, lessors, lessees, ridesharing entity,
employers, agents, or owners of motor
vehicles), and ABC CORP. 1-5 (fictitiously
named operators, lessors, lessees, ridesharing
entity, employers, agents, or owners of motor
vehicles),
Defendants.
I, Louis M. Gerbino, Esq., of full age, hereby certify as follows:
1 Tam an Attorney at Law of the State of New Jersey and an associate of HANNA |
PEREZ, PC, attorneys for plaintiff, JEEDALLAH H. DAGHASH, in the above matter. I am
entrusted with the handling of this matter to conclusion and am fully familiar with the facts delineated
herein.
2. Plaintiff instituted suit in this matter on September 1, 2023 for personal injuries and other
losses, arising out of a motor vehicle accident, which occurred September 11, 2021 in Paramus, New
Jersey.
BER-L-004731-23 10/31/2023 4:23:14PM Pg3of3 Trans ID: LCV20233259155
3 Plaintiff caused the Summons and Complaint in this matter to be served upon
defendants, ADILA Z. MANSOORI and JUAN GONZALEZ, on September 7, 2023 and September
13, 2023, respectively. See ExhibitA, Affidavits of Service as to the defendants.
4. The time within which the aforesaid defendants may answer or otherwise move as to
the Complaint has expired and has not been further extended or enlarged by consent or by Court
Order.
5 Pursuant to R. 4:43-1, plaintiff, JEEDALLAH H. DAGHASH, therefore respectfully
requests that the Court enter default as to defendants, ADILA Z. MANSOORI and JUAN
GONZALEZ, at this time.
I cettify the foregoing statements ate true. I am awate if any statement made herein is willfully
false, I am subject to punishment.
Ae fe 2 LOUIS M. GERBINO, ESQ.
Dated: October 31, 2023
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BER-L-004731-23 10/31/2023 4:23:14PM Pglof3 Trans ID: LCV20233259155 Louis M. Gerbino, Esq., Attorney ID No. 196862016 HANNA | PEREZ rc 185 Route 17 South Paramus, New Jersey 07652 (201) 224-9400, Fax: (201) 224-9401 Attomey for Plaintiff, JEEDALLAH H. DAGHASH SUPERIOR COURT OF NEW JERSEY JEEDALLAH H. DAGHASH, LAW DIVISION: BERGEN COUNTY Plaintiff, DOCKET NO.: BER-L-4731-23 vs. Civil Action JUAN GONZALEZ, SUSAN J. JAEGER, ELIZABETH G. QUIMBY, ADILA Z. REQUEST TO ENTER DEFAULT MANSOORI, JOSHUA F. HOSINE, DRIVE NEW JERSEY INSURANCE COMPANY, JOHN DOES 1-5 (fictitiously named operators, lessors, lessees, ridesharing entity, employers, agents, or owners of motor vehicles), and ABC CORP. 1-5 (fictitiously named operators, lessors, lessees, tidesharing entity, employers, agents, or owners of motor vehicles), Defendants. TO THE CLERK OF THE ABOVE NAMED COURT: PLEASE enter the default of the defendants, ADILA Z. MANSOORI and JUAN GONZALEZ, for failure to plead or otherwise defend as provided by the Rules of Civil Practice of the Superior Court or by an Order of this Court. A certification in support of this request is attached. HANNA | PEREZ PC Attorneys for Plaintiff PO Bo LOUIS M. GERBINO, ESQ. Dated: October 31, 2023 BER-L-004731-23 10/31/2023 4:23:14PM Pg2of3 Trans ID: LCV20233259155 Louis M. Gerbino, Esq., Attorney ID No. 196862016 HANNA | PEREZ rc 185 Route 17 South Paramus, New Jetsey 07652 (201) 224-9400, Fax: (201) 224-9401 Attomey for Plaintiff, JEEDALLAH H. DAGHASH SUPERIOR COURT OF NEW JERSEY JEEDALLAH H. DAGHASH, LAW DIVISION: BERGEN COUNTY Plaintiff, DOCKET NO.: BER-L-4731-23 vs. Civil Action JUAN GONZALEZ, SUSAN J. JAEGER, ELIZABETH G. QUIMBY, ADILA Z. CERTIFICATION OF LOUIS M. MANSOORI, JOSHUA F. HOSINE, DRIVE GERBINO NEW JERSEY INSURANCE COMPANY, JOHN DOES 1-5 (fictitiously named operators, lessors, lessees, ridesharing entity, employers, agents, or owners of motor vehicles), and ABC CORP. 1-5 (fictitiously named operators, lessors, lessees, ridesharing entity, employers, agents, or owners of motor vehicles), Defendants. I, Louis M. Gerbino, Esq., of full age, hereby certify as follows: 1 Tam an Attorney at Law of the State of New Jersey and an associate of HANNA | PEREZ, PC, attorneys for plaintiff, JEEDALLAH H. DAGHASH, in the above matter. I am entrusted with the handling of this matter to conclusion and am fully familiar with the facts delineated herein. 2. Plaintiff instituted suit in this matter on September 1, 2023 for personal injuries and other losses, arising out of a motor vehicle accident, which occurred September 11, 2021 in Paramus, New Jersey. BER-L-004731-23 10/31/2023 4:23:14PM Pg3of3 Trans ID: LCV20233259155 3 Plaintiff caused the Summons and Complaint in this matter to be served upon defendants, ADILA Z. MANSOORI and JUAN GONZALEZ, on September 7, 2023 and September 13, 2023, respectively. See ExhibitA, Affidavits of Service as to the defendants. 4. The time within which the aforesaid defendants may answer or otherwise move as to the Complaint has expired and has not been further extended or enlarged by consent or by Court Order. 5 Pursuant to R. 4:43-1, plaintiff, JEEDALLAH H. DAGHASH, therefore respectfully requests that the Court enter default as to defendants, ADILA Z. MANSOORI and JUAN GONZALEZ, at this time. I cettify the foregoing statements ate true. I am awate if any statement made herein is willfully false, I am subject to punishment. Ae fe 2 LOUIS M. GERBINO, ESQ. Dated: October 31, 2023