Document for Cates Lori Vs Oh Kenneth

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                                BER-L-001125-22 08/31/2023 9:56:01 PM Pg 1 of 5 Trans ID: LCV20232501533




New Jersey                                                                    New York
570 W. Mt. Pleasant Avenue                                                   101 Greenwich Street, 20th Floor
Livingston, NJ 07039                                                         New York, NY 10006

P: 973-422-9600                      Please reply to the New Jersey office   P: 212-363-6900
F: 973-422-9666                                                              F: 212-363-1090
                                          www.gsbwlaw.com

                                               August 31, 2023

Via eCourts
Hon. David V. Nasta, J.S.C.
Bergen County Justice Center
10 Main Street
Floor 3
Hackensack, NJ 07601

          RE:       Lori Cates v. Kenneth Oh, et al.
                    Docket No.: BER-L-1125-22
                    File No.: 18960-MRJ

Dear Judge Nasta:

       Please be advised that this firm represents Defendant, Kenneth Oh, in the above-referenced
matter. Presently returnable before Your Honor is Plaintiff’s Motion to Extend Discovery and
Compel the Deposition of Kenneth Oh. As set forth in correspondence from Plaintiff’s counsel
dated August 23, 2023 (Trans ID: LCV20232418263), the portion of Plaintiff’s motion to compel
discovery responses from Kenneth Oh was withdrawn as the requested discovery responses were
provided. Please accept this letter brief as Kenneth Oh’s intent to join in the portion of Plaintiff’s
motion to extend discovery and in opposition to the portion of Plaintiffs’ motion seeking to compel
deposition.

        Defendant, Kenneth Oh, does not oppose Plaintiff’s motion to extend discovery, but rather
joins in this portion of the motion. Additional time for discovery is needed in this matter in order
to complete party depositions, exchange expert reports, and conduct expert depositions, if needed.

        However, Defendant, Kenneth Oh, hereby opposes Plaintiff’s proposed form of Order
seeking to compel Kenneth Oh’s deposition for September 6, 2023. Mr. Oh is currently recovering
after undergoing back surgery last week. This office will coordinate with counsel and agrees to
conduct Mr. Oh’s deposition within 30 days of the date of the Order in order to permit Mr. Oh
time to recover from his surgery. An alternative form of Order is attached hereto as Exhibit A.

       Based on the above, Defendant, Kenneth Oh, respectfully requests that the discovery period
be extended for ninety (90) days until November 27, 2023.

       Furthermore, in light of the foregoing, Defendant, Kenneth Oh, respectfully requests that
the Court deny the portion of Plaintiff’s motion seeking to compel Kenneth Oh’s deposition for
September 6, 2023, and enter the alternative form of Order submitted herewith.
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       Thank you for Your Honor’s time and consideration.

                                   Respectfully submitted,

                                   GOETZ SCHENKER BLEE & WIEDERHORN, LLP

                                   Stephanie M. Hehman
                                   Stephanie M. Hehman, Esq.

cc:    Jared E. Drill, Esq.
       Renee F. McCaskey, Esq.
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               EXHIBIT A
        BER-L-001125-22 08/31/2023 9:56:01 PM Pg 4 of 5 Trans ID: LCV20232501533




GOETZ SCHENKER BLEE & WIEDERHORN, LLP
Attorneys for Defendant, Kenneth Oh
570 West Mt. Pleasant Avenue – Suite 201
Livingston, New Jersey 07039
Phone: (973) 422-9600
Fax: (973) 422-9666
www.gsbwlaw.com
File No: 18960-MRJ
Attorney I.D. 033902010 – Stephanie M. Hehman, Esq.

 LORI CATES,                                             SUPERIOR COURT OF NEW JERSEY
                                                         LAW DIVISION: BERGEN COUNTY
 Plaintiff,                                              DOCKET NO. BER-L-1125-22

 -vs-
                                                                      Civil Action
 KENNETH         OH,       DELTA        INTERIOR
 CONSTRUCTION, INC., BOROUGH OF
 RUTHERFORD, COUNTY OF BERGEN, ABC                                         ORDER
 CORPORATION 1-10, ABC MAINTENANCE
 1-10 and JOHN/JANE DOES 1-10 (last four
 names being fictitious and presently unknown),

 Defendants.

         THIS MATTER having been opened to the Court by Goetz Schenker Blee & Wiederhorn,

LLP, attorneys for Defendant, Kenneth Oh, for an Order extending the discovery period, with said

motion being made and served in accordance with Rule 1:6-2, and with the consent of all parties,

and the Court having reviewed the moving papers and for good cause shown:

         IT IS ON THIS ________ day of _______________________, 2023;

         ORDERED that the deposition of Defendant Kenneth Oh shall be conducted with thirty

(30) days of the date of this Order; and it is further

         ORDERED that the discovery period is hereby extended for ninety (90) days until

November 27, 2023; and it is further

         ORDERED that discovery shall be completed as follows:

         1. Plaintiff’s expert reports to be served by October 15, 2022;
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       2. Defendants’ expert reports to be served by November 15, 2023; and

       3. Expert depositions, if any, to be completed by November 27, 2023.

       IT IS FURTHER ORDERED that a copy of this Order shall be served upon all counsel

of record via the e-Courts electronic filing system.


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