Preview
CAM-L-000221-23 03/27/2023 5:17:55 PM Pglof1l Trans ID: LCV20231043642
O'TOOLE SCRIVO LLC
Steven A. Weiner, Bar ID # 012811975
14 Village Park Road
Cedar Grove, NJ 07009
973-239-5700
Fax 973-239-3400
Attorneys for Defendants J&J AUTO OUTLET T/A
AUTO CONCEPTS, MICHAEL GARRO, JOE GALLO
SUPERIOR COURT OF NEW JERSEY
JULIA ROSE NAWROCKI, INDIVIDUALLY AND LAW DIVISION: CAMDEN COUNTY
ON BEHALF OF ALL OTHERS SIMILARLY Docket No.: CAM-L-221-23
SITUATED,
CIVIL ACTION
Plaintiff,
vs.
J&J AUTO OUTLET T-A AUTO CONCEPTS,
MICHAEL GARRO, JOE GALLO AND JOHN
DOES 1-10,
Defendant(s)
REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS COMPLAINT
AND COMPEL ARBITRATION
AND IN OPPOSITION TO CROSSMOTION BY PLAINTIFF
Steven A. Weiner, Esq.,
Of Counsel
Peter V. Koenig, Esq.,
On the Brief
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PRELIMINARY STATEMENT
By the present Motion, the defendants seek an Order dismissing plaintiffs Complaint and
referring the matter to the currently pending arbitration proceeding.
The defense Motion is based upon the contract documents plaintiff signed in connection
with her purchase of the vehicle. These include the Buyer’s Guide provided to plaintiff, which she
signed, as well as the Service Contract she also signed. The Service Contract is the Dealer
Warranty she purchased from the dealer when she purchased the vehicle.
Plaintiff's opposition and Crossmotion are based upon an inexplicable, and likely false,
denial that the Buyer’s Guide existed, and an implicit denial that she signed that document. The
opposition and Crossmotion also flatly contradict the allegations of the Complaint, in which
plaintiff asserts claims for breach of the Dealer Warranty / Service Contract that she admits
signing.
The defense Motion should be granted, and the matter directed to arbitration under the
Dealer Warranty / Service Contract signed by the parties. The Crossmotion should be denied as
flatly contradicting the contract documents and the allegations of the Complaint.
If there is any question regarding the authenticity of the Buyer’s Guide or the plaintiff's
signature on that document — and we do not concede such a question exists — then the defense
would welcome a hearing at which the defendant will testify as to the authenticity of plaintiff's
signature, and would seek sanctions remedies under R. 4:46-5(b).
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SUMMARY OF MATERIAL FACTS
The facts material to the present Motion and Crossmotion are set forth in the accompanying
Responses to Plaintiff's Statements of Fact and Counterstatements “Responses”, The Certification
of Joe Gallo dated February 28, 2023 (Gallo Cert.), and the Reply Certification of Joe Gallo with
its Exhibits (Gallo Reply”), which are incorporated herein by reference. To summarize some of
the key facts:
Plaintiff purchased the vehicle from the dealer, with a “Dealer Warranty” issued on behalf
of the dealer. Responses, § 5 and Gallo Reply Exhibits 1 and 2; see Gallo Cert., Exhibits 1 and 2.
That is, the “Service Contract” is the Dealer Warranty. Gallo Reply, Js 7 and 8.
The Dealer Warranty / Service Contract is specified in the Buyers Guide for the transaction.
Gallo Reply, fs 1 through 4 and Exhibit 2 (copy of Buyer’s Guide signed by plaintiff).
The Buyer’s Guide was displayed in plain view on the vehicle. Gallo Reply, § 2.
The plaintiff received and signed a copy of the Buyer’s Guide at the time of purchase.
Gallo Reply, § 1 and Exhibit 2 (copy of Buyer’s Guide with plaintiffs signature.)
The cost of the Dealer Warranty / Service Contract was included in the purchase price of
the vehicle. Gallo Reply, § 9 and “Buyer’s Order.”
The Dealer Warranty / Service Contract was part of the same transaction by which plaintiff
purchased the vehicle. Gallo Reply, 4 7.
As stated in the Buyer’s Guide signed by plaintiff (Gallo: Reply, Exhibit 2), there was no
“Non-Dealer Warranty” for the vehicle. Gallo Reply, § 10. As stated in the Buyer’s Guide signed
by plaintiff, there was no “separate service contract available for the vehicle at an extra charge.”
Gallo Reply, Exhibit 2 and f 11.
The dealer is a party to the Dealer Warranty, which is the Service Contract. Gallo Reply,
q 10.
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Plaintiff received, accepted and signed the Service Contract, as the Dealer Warranty for
the vehicle. Gallo Cert., Exhibits 1 and 2.
The Dealer Warranty / Service Contract (Gallo Cert., Exhibits 1 and 2) includes an
arbitration provision binding the dealer and the plaintiff. The initial page of the Dealer Warranty
/ Service Contract states, in pertinent part:
DISCLOSURES
FRR
4. Your Contract contains an arbitration clause which may affect Your legal rights,
unless You live in a stale that prohibits such provisions. Please review the
arbitration in its entirety as well as the Stale Requirements section for Your specific
state (if Your state is included) to determine whether Your legal rights are affected.
The Dealer Warranty / Service Contract provides for mandatory binding arbitration:
9. ARBITRATION
READ THE FOLLOWING ARBITRATION PROVISION CAREFULLY. IT LIMITS
CERTAIN RIGHTS, INCLUDING YOUR RIGHT TO OBTAIN RELIEF OR
DAMAGES THROUGH COURT ACTION.
To begin Arbitration, either You or We must make a written demand to the other party for
Arbitration. The Arbitration will take place before a single arbitrator. It will be administered in
keeping with the Expedited Procedures of the Commercial Arbitration Rules ("Rules") of the
American Arbitration Association ("AAA") in effect when the Claim is filed . You may get a
copy of these AAA's Rules by contacting AAA at J 633 Broadway, 10th Floor, New York, NY
10019, calling 1 800 778 7879 or visiting www.adr.org. The filing fees to begin and carry out
Arbitration will be shared equally between You and Us. This does not prohibit the arbitrator
from giving the winning party their fees and expenses of the arbitration. Unless You and We
agree, the arbitration will take place in the county and state where You live. The Federal
Arbitration Act, 9 U.S.C. § 1, et seq., will govern and no state, local or other arbitration law
will apply. You AGREE AND UNDERSTAND THAT this Arbitration provision means
that You give up Your right to go to court on any Claim covered by this provision. You
also agree that any Arbitration proceeding will only consider Your Claims. Claims by, or on
behalf of, other individuals will not be arbitrated in any proceeding that is considering Your
Claims. Please refer to the Special State Disclosure of this Service Contract for any added
requirements in Your state. In the event this Arbitration provision is not approved by the
appropriate state regulatory agency, and/or is stricken, severed, or otherwise deemed
unenforceable by a court of competent jurisdiction, You and We specifically agree to waive
and forever give up the right to a trial by jury. Instead, in the event any litigation arises between
You and Us, any such lawsuit will be tried before a judge, and a jury will not be impaneled or
struck.
The Dealer Warranty / Service Contract specifically identifies the dealer as follows:
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DEALER: Refers to the party who sold You this Service Contract. Please see the box labeled
"Dealer Name" on the Registration Page for Your Dealer's contact information.
The “Dealer” is specified on the first page of the Dealer Warranty / Service Contract as “Auto
Concepts,” which is Auto Concepts, Incorporated — the “dealer” defendant named in the
Complaint.
Plaintiffs Complaint in this action is based upon alleged breaches of warranty — that is, the
Dealer Warranty / Service Contract sold by the dealer as part of the sale of the vehicle. The term,
“warranty” and related statutes appear at least 40 times in the Complaint. See, e.g., p. 3 Js “R”
and “T”; page 9 Js 34, 35 and 36; p. 10 §s 38 and 41; pp. 32-33 §s190; p. 35 196; p, 39 § 203; p.
56 9251;p. 58 4 158.
The substance of plaintiff's claims for breach of warranty are alleged at pp. 12 to 15. at Js
50 through 88; some 39 paragraphs.
In sum: the dealer sold and plaintiff purchased the vehicle with a Dealer Warranty, which
was the “Service Contract.” The Warranty / Service Contract was an integral part of the transaction
between the dealer and the plaintiff. It was not a separate transaction. Plaintiff received and signed
the Buyer Guide specifying the Dealer Warranty, as well as the Dealer Warranty / Service Contract
itself. Plaintiff asserts claims for breach of the Dealer Warranty / Service Contract. Plaintiff's
claims are subject to arbitration under the terms of Dealer Warranty / Service Contract.
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LEGAL ARGUMENT
POINT I
THIS COURT DECIDES THE THRESHOLD QUESTION
OF ARBITRABILITY
There is no dispute as to this proposition of law. The first “Point” of the brief for plaintiff
appears to erect a “straw man” by discussing it. The defendants’ Motion seeks a determination
that the dispute be referred to arbitration as provided by the governing contract documents —
including without limitation the Buyer’s Guide that plaintiff received and signed.
It beggars the imagination to see that plaintiff now claims the Buyer’s Guide did not exist,
and that she never saw it. The defense has produced a copy of this document, signed by the
plaintiff. Gallo Reply, Exhibit 2. The defense reserves the right to apply for sanctions pursuant to
R. 4:46-5(b).
It is also troubling that the Complaint alleged only:
40. Upon information and belief, at time of sale, defendants failed to display a
buyers guide in the window of the vehicle or anywhere on the vehicle or in close
proximity thereto and failed to give any such buyers guide to plaintiffs.
ek
193. Upon information and belief, at time of sale, there was no buyers guide
displayed in the window of the vehicle, on the body of the vehicle or in close
proximity to the vehicle or at the main entrance(s) to the business premises where
the vehicle was displayed and defendants never gave plaintiffs any buyers guide
for the vehicle.
[emphases added]
Whose “information and belief’ does the Complaint rely upon? That of counsel? Plaintiffs
Certification states that she only provided counsel with the “Buyers Order” and the “Vehicle
Service Contract.” Certification of Litigant, § 3. She did not provide counsel with the Buyer’s
Guide that bears her signature.
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Plaintiff belatedly asserts, in opposition to this Motion, that there was no “Buyer’s Guide”
and that she never received one. Certification of Litigant, { 8. This is flatly contradicted and
disproven by the Buyer’s Guide that she received and signed — but did not provide to her attorneys.
In { 9, plaintiff retreats and prevaricates by claiming that she “never saw” a Buyer’s Guide.
This is likewise disproven, as a documentary fact, by the Buyer’s Guide she received and signed.
That she now claims not to recall seeing it does not mean that it did not exist.
In { 12, plaintiff asserts that she “never bought any service contract from the dealer. The
Service Contract itself, which she signed, specifically identifies the “Dealer” as follows:
DEALER: Refers to the party who sold You this Service Contract. Please see the
box labeled "Dealer Name" on the Registration Page for Your Dealer's contact
information.
The first page of the Service Contract identifies Auto Concepts, Incorporated as, in haec verba,
the “Dealer ... who sold You (plaintiff) this Service Contract.”
We do not concede that there is a bona fide question of fact as to the documents that
plaintiff signed. If, however, plaintiff seriously claims that her signatures are forgeries or the like,
then we welcome a hearing at which Mr. Gallo and others would testify as to the authenticity of
the documents — the Buyer’s Guide, the Service Contract, and the other documents plaintiff signed
incident to the purchase of the vehicle. The defense would certainly pursue its rights under R.
4:46-5(b) when, as seems inevitable, plaintiff's Certification is proven to have been false.
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POINT II
THE DEALER WARRANTY / SERVICE CONTRACT
IS SUPPORTED BY CONSIDERATION
Plaintiffs opposition to the defense Motion, and plaintiffs Crossmotion, are erected upon
a foundation of sand. Plaintiff signed the Buyer’s Guide. Plaintiff also signed the Service
Contract. The Service Contract — being the Dealer Warranty — was not a separate transaction.
The consideration for the Service Contract was the purchase price of the vehicle. These
were not two separate transactions. Indeed, the Buyer’s Guide stated that the vehicle was sold
with a Dealer Warranty — specified in the Buyer’s Guide as the Service Contract, which plaintiff
also signed.
The Dealer is specifically identified in the Service Contract as the party from which
plaintiff purchased the Service Contract. The Buyer’s Guide confirmed that there was no separate
service contract on offer for the vehicle, and no separate charge for such a contract. Again, as
stated in the contract documents and confirmed by Mr. Gallo’s Reply Certification, the cost of the
Service Contract (as the Dealer Warranty) was included in the price of the vehicle.
The provision of the Dealer Warranty / Service was not a gift to the plaintiff. It was bought
and paid for as part of the purchase price of the vehicle. This was the basis on which the vehicle
was offered for sale.
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POINT II
THE DEFENSE MOTION IS NOT BASED UPON
A MISTAKE OR OMISSION IN THE PLEADING
The defense Motion is for Dismissal and referral to arbitration. The defense does not argue
that the Complaint is flawed in itself. Instead, the parties’ contract documents provide for
mandatory arbitration — under the applicable Dealer’s Warranty / Service Contract which plaintiff
signed and accepted, as designated by the Buyer’s Guide that plaintiff also signed and accepted.
Repleading or amendment of the Complaint would not address the basis for the Motion.
Put colloquially, it is not what the Complaint failed to say, but the governing documents that
plaintiff's Complaint ignores.
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POINT IV
THE PLAINTIFF’S CROSSMOTION HUST BE DENIED BECAUSE
PLAINTIFF HAS NOT EXCLUDED ISSUES OF FACT
This is an over-generous description of the Crossmotion. It is based upon assertions that
are flatly contrary to fact — such as plaintiffs denial of the Buyer’s Guide that she signed, and her
denial that she “bought anything” from the Dealer by way of a warranty under the Service Contract
which she signed and which specifically identifies the Dealer as “the party who sold You this
Service Contract.”
Likewise, plaintiff's Crossmotion is based upon a repudiation of the Complaint itself. In
the Complaint, plaintiff asserts against the dealer dozens of alleged violations of the Dealer
Warranty / Service Contract. The Complaint invokes a host of warranty-based statutes — over forty
(40) allegations including the term, “warranty.” The Complaint makes some thirty-none specific
allegations of failure to perform warranty repairs. Now, in opposition to the defense Motion and
in support of plaintiff's Crossmotion, plaintiff argues that the Service Contract — which is the
Dealer Warranty — does not govern her claims, and that the dealeris a stranger to the very Service
Contract she claims was breached.
Repudiation of pleadings and denial of the existence of signed contract documents cannot
form the basis for a grant of Partial Summary Judgment for plaintiff.
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CONCLUSION
The contract documents signed by plaintiff are clear, and binding. The vehicle was sold
with a Dealer Warranty, as a single transaction. The Service Contract is that Warranty. The
Service Contract contains an arbitration provision that should be enforced. Denying the existence
of signed contract documents, or ignoring their provisions, must not deter or delay the agreed-upon
arbitration process.
For the reasons set forth herein, and in the prior submission on their behalf, the defendants
respectfully urge that the Complaint be dismissed in its entirety, with prejudice, pursuant to R. 4:6-
2(e), and the plaintiff be ordered to proceed in the pending arbitration proceeding before the
American Arbitration Association under Case Number: 01-23-0000-7958.
Respectfully submitted,
O’TOOLE SCRIVO, LLC
Attorneys for Defendants
Auto Concepts, Inc. trading as J&J Auto Outlet,
Michael Garro and Joseph Gallo
By: /s/ Steven A. Weiner
Steven A. Weiner
DATED: March 27, 2023
10
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O'TOOLE SCRIVO LLC
Steven A. Weiner, Bar ID # 012811975
14 Village Park Road
Cedar Grove, NJ 07009
973-239-5700
Fax 973-239-3400
Attorneys for Defendants J&J AUTO OUTLET T/A
AUTO CONCEPTS, MICHAEL GARRO, JOE GALLO
JULIA ROSE NAWROCKI, INDIVIDUALLY AND SUPERIOR COURT OF NEW JERSEY
ON BEHALF OF ALL OTHERS SIMILARLY LAW DIVISION: CAMDEN COUNTY
SITUATED, Docket No.: CAM-L-221-23
Plaintiff, CIVIL ACTION
vs.
J&J AUTO OUTLET T-A AUTO CONCEPTS,
REPLY CERTIFICATION OF JOE
MICHAEL GARRO, JOE GALLO AND JOHN
GALLO IN FURTHER SUPPORT OF
DOES 1-10,
MOTION TO DISMISS COMPLAINT
Defendant(s) AND IN OPPOSITION TO
CROSSMOTION
Joe Gallo, of full age, hereby certifies and says:
1 Iam a principal of AUTO CONCEPTS, INC. (“Auto Concepts”) which trades as J&J
AUTO OUTLET (“J&J”) — collectively, the “Dealer”. As such, | am a custodian the business
records referred to in this Certification. I am also named personally as a defendant.
oi2. I am familiar the documents relating to the transaction with Plaintiff.
3. Exhibit 1 is a copy of a document entitled, “Tips on Buying a Used Car” prepared and
published by the New Jersey Division of Consumer Affairs. I have highlighted the paragraph
describing the “Buyer’s Guide.”
4, Exhibit 2 is a copy of the Buyer’s Guide for plaintiff's purchase of the vehicle involved
in this action. On the attached copy, I have circled the heading “Buyer’s Guide.” and also the
signature of plaintiff Julia Nawrocki.
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5. The Buyer’s Guide was posted in plain view on the vehicle purchased by Ms:
Nawrocki. She was given a copy of this document at the time of sale
6. Exhibit 3 comprises several other documents signed by plaintiff Julia Nawrocki when
she purchased the vehicle:
° New Jersey Motor Vehicle Commission Universal Title Application
Odometer Disclosure Statement
Buyer’s Order
Sale Receipt
Contract Registration Page
Notarized Power of Attorney for transferring title and registration of the vehicle
e New Jersey Motor Vehicle Commission Application for Registration
On each of these, I have circled the signature of plaintiff Julia Nawrocki
7. The Dealer’s Warranty was part of the same transaction in which Ms. Nawrocki
purchased the vehicle and is the same warranty referenced on the Buyer’s Guide (copy attached).
8. The Vehicle purchased by Ms. Nawrocki came with a Dealer Warranty (see attached
.
‘Buyers Guide”)
9. The cost of the Service Contract, as shown on the Contract Registration Page, was
included in the “Selling Price” of $19,995.00 (see Buyer’s Order - copy attached)
10. The “Dealer” is a party to the Service Contract that Ms. Nawrocki purchased.
I certify that the foregoing statements made by me is true. | ‘am aware that if the
foregoing statements made by me is willfully false, 1 am subject to punishment,
Chaat
Joe Gallo ”
ALE
Dated: March 23, 2023
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EXHIBIT 1—
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Tips on Buying a >»)
Used Car
DZ
consumer brief”
The purchase of a used car can be a high-cost THE USED CAR BUYER'S GUIDE
consumer transaction. Here is what you should know Look for the Buyer’sGi | the ind Fc ehicle
before making your purchase. you're consi ring ecrihies
equir¢
THE USED CAR LENION LAW posted i view sale,
The gui nforms th aL abou Is f the
Ifa New Jersey dealer sells you a used car that is defective, ‘warrant if one exists, ‘if the | “AS- ”»
you mar be eligible for relief under the Used Car Lemon
h
Law. T! he law requires the dealer to provide a limiced
Cars sold “AS-IS” do not come with any warranry, either
expressed or implied. The guide will disclose if there is any
warranty if the car is — not more than seven (7) years old; remaining manufacturer's warranty on the vehicle, and ifan
has less than 100,000 miles; the price is over $3,000; and/ extended service contract is availabl co} F the guide
or the car has not been declared a total Joss by an insurance should be given to you at the time of purchase.
company. If the car has 60,000 miles on its odometer and
the consumer wishes to waive the warranty to negotiate a FINDING THE BEST PRICE
better price, che consumer must sign a form that he/she is You should always shop around and negotiate for the best
buying che car withouc a warranty. The warranty covers price. Visit several dealerships and don’t be in a hurry.
certain components of the engine, transmission and the Used car pricing guides may be found at your local library,
front—_ or rear-wheel drive. If you have experienced three bookstore or even online. A current guide will tell you the
(3) repair attempts on a covered item within the dealer's used car's retail or trade-in value. You may also be able to
warranty period, ou may qualify fora Lemon Law hearing.
fi
The duration o} the dealer's warranty to which you are
find a good deal from ¢ privare seller, but keep in mind
thac those cars do not come with any warranty and are not
enticled depends on the car's mileage at the time of sale. subject to the Used Car Lemon Law. 3
See the information below.
fa
Vehicle Mileage Duration of Dealer Warranty Continued
Less than 24,000 miles. 90 days or 3,000 miles
24,000 miles to 60,000 miles. 60 days or 2,000 miles ciesa
Roprasentatn}
(Signature oF Co-Buyor)
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AUTO CONCCPTS
220 £ EVESHAM ROAD
sy GLENDORA, N* OB023 |
Merchant 10: (572
Term Ws WOOL Store Il: GOU1
Ref tH: G862
Sale
AXXKANXXXXAN2488
VISA Entry Hethod: Chip
Total: § 2,000.00
09/20/22 17:00:07
Inv ts 000002 Appr Code: 084930
Transaction ID: 582263756071885
Apprvd: Online Batchi: 600067
CAPITAL ONE VISA
AID: 40008008031010
TSI: £806
TR: 6000008000
I agree to pay above total
amount according to ca rd issuer
ayreenen reement if
credit voucher)
AWROCK1/JULIA
Nerchant Copy
CAM-L-000221-23 03/27/2023 5:17:55 PM Pg6of8 Trans ID: LCV20231043642
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J & J AUTO OUTLET/TA AUTO CONCEPTS
220 EVESHAM RD
GLENDORA, NJ 08029
the POWER OF ATTORNEY ie
Date: 9/20/22
I constitute and appoint Joseph Gallo ox Michael Garro,
my (our) true and lawful attorney-in-fact for the purpose of
transferring title and registration, assignment of title, and
applications for titles to the above described motor vehicle
with full authority to sign on my (our) behalf all papers and
documents. and to do all things necessary to this, appointment.
Customer: JULIA R NAWROCKI
115 PENN AVE
COLLINGSWOOD, NJ 08108
Owner Of: 12 DODGE RAM 1500; GREEN
Vin: 1C6RD7LT5CS8329075
Executed on this date: 9/20/22
Signed ee) Af} /E— “
er
ined —.
TN L STARR
BRAND
Commiss ion #2448608 Jersey
e of New
Publlo, Stor
NotaryMy.Comm 18910 pexpires
August 04,
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CAM-L-000221-23 03/27/2023 5:17:55 PM Pglof1l Trans ID: LCV20231043642 O'TOOLE SCRIVO LLC Steven A. Weiner, Bar ID # 012811975 14 Village Park Road Cedar Grove, NJ 07009 973-239-5700 Fax 973-239-3400 Attorneys for Defendants J&J AUTO OUTLET T/A AUTO CONCEPTS, MICHAEL GARRO, JOE GALLO SUPERIOR COURT OF NEW JERSEY JULIA ROSE NAWROCKI, INDIVIDUALLY AND LAW DIVISION: CAMDEN COUNTY ON BEHALF OF ALL OTHERS SIMILARLY Docket No.: CAM-L-221-23 SITUATED, CIVIL ACTION Plaintiff, vs. J&J AUTO OUTLET T-A AUTO CONCEPTS, MICHAEL GARRO, JOE GALLO AND JOHN DOES 1-10, Defendant(s) REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS COMPLAINT AND COMPEL ARBITRATION AND IN OPPOSITION TO CROSSMOTION BY PLAINTIFF Steven A. Weiner, Esq., Of Counsel Peter V. Koenig, Esq., On the Brief CAM-L-000221-23 03/27/2023 5:17:55 PM Pg2of1l1 Trans ID: LCV20231043642 PRELIMINARY STATEMENT By the present Motion, the defendants seek an Order dismissing plaintiffs Complaint and referring the matter to the currently pending arbitration proceeding. The defense Motion is based upon the contract documents plaintiff signed in connection with her purchase of the vehicle. These include the Buyer’s Guide provided to plaintiff, which she signed, as well as the Service Contract she also signed. The Service Contract is the Dealer Warranty she purchased from the dealer when she purchased the vehicle. Plaintiff's opposition and Crossmotion are based upon an inexplicable, and likely false, denial that the Buyer’s Guide existed, and an implicit denial that she signed that document. The opposition and Crossmotion also flatly contradict the allegations of the Complaint, in which plaintiff asserts claims for breach of the Dealer Warranty / Service Contract that she admits signing. The defense Motion should be granted, and the matter directed to arbitration under the Dealer Warranty / Service Contract signed by the parties. The Crossmotion should be denied as flatly contradicting the contract documents and the allegations of the Complaint. If there is any question regarding the authenticity of the Buyer’s Guide or the plaintiff's signature on that document — and we do not concede such a question exists — then the defense would welcome a hearing at which the defendant will testify as to the authenticity of plaintiff's signature, and would seek sanctions remedies under R. 4:46-5(b). CAM-L-000221-23 03/27/2023 5:17:55 PM Pg3o0f11 Trans ID: LCV20231043642 SUMMARY OF MATERIAL FACTS The facts material to the present Motion and Crossmotion are set forth in the accompanying Responses to Plaintiff's Statements of Fact and Counterstatements “Responses”, The Certification of Joe Gallo dated February 28, 2023 (Gallo Cert.), and the Reply Certification of Joe Gallo with its Exhibits (Gallo Reply”), which are incorporated herein by reference. To summarize some of the key facts: Plaintiff purchased the vehicle from the dealer, with a “Dealer Warranty” issued on behalf of the dealer. Responses, § 5 and Gallo Reply Exhibits 1 and 2; see Gallo Cert., Exhibits 1 and 2. That is, the “Service Contract” is the Dealer Warranty. Gallo Reply, Js 7 and 8. The Dealer Warranty / Service Contract is specified in the Buyers Guide for the transaction. Gallo Reply, fs 1 through 4 and Exhibit 2 (copy of Buyer’s Guide signed by plaintiff). The Buyer’s Guide was displayed in plain view on the vehicle. Gallo Reply, § 2. The plaintiff received and signed a copy of the Buyer’s Guide at the time of purchase. Gallo Reply, § 1 and Exhibit 2 (copy of Buyer’s Guide with plaintiffs signature.) The cost of the Dealer Warranty / Service Contract was included in the purchase price of the vehicle. Gallo Reply, § 9 and “Buyer’s Order.” The Dealer Warranty / Service Contract was part of the same transaction by which plaintiff purchased the vehicle. Gallo Reply, 4 7. As stated in the Buyer’s Guide signed by plaintiff (Gallo: Reply, Exhibit 2), there was no “Non-Dealer Warranty” for the vehicle. Gallo Reply, § 10. As stated in the Buyer’s Guide signed by plaintiff, there was no “separate service contract available for the vehicle at an extra charge.” Gallo Reply, Exhibit 2 and f 11. The dealer is a party to the Dealer Warranty, which is the Service Contract. Gallo Reply, q 10. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg4of11 Trans ID: LCV20231043642 Plaintiff received, accepted and signed the Service Contract, as the Dealer Warranty for the vehicle. Gallo Cert., Exhibits 1 and 2. The Dealer Warranty / Service Contract (Gallo Cert., Exhibits 1 and 2) includes an arbitration provision binding the dealer and the plaintiff. The initial page of the Dealer Warranty / Service Contract states, in pertinent part: DISCLOSURES FRR 4. Your Contract contains an arbitration clause which may affect Your legal rights, unless You live in a stale that prohibits such provisions. Please review the arbitration in its entirety as well as the Stale Requirements section for Your specific state (if Your state is included) to determine whether Your legal rights are affected. The Dealer Warranty / Service Contract provides for mandatory binding arbitration: 9. ARBITRATION READ THE FOLLOWING ARBITRATION PROVISION CAREFULLY. IT LIMITS CERTAIN RIGHTS, INCLUDING YOUR RIGHT TO OBTAIN RELIEF OR DAMAGES THROUGH COURT ACTION. To begin Arbitration, either You or We must make a written demand to the other party for Arbitration. The Arbitration will take place before a single arbitrator. It will be administered in keeping with the Expedited Procedures of the Commercial Arbitration Rules ("Rules") of the American Arbitration Association ("AAA") in effect when the Claim is filed . You may get a copy of these AAA's Rules by contacting AAA at J 633 Broadway, 10th Floor, New York, NY 10019, calling 1 800 778 7879 or visiting www.adr.org. The filing fees to begin and carry out Arbitration will be shared equally between You and Us. This does not prohibit the arbitrator from giving the winning party their fees and expenses of the arbitration. Unless You and We agree, the arbitration will take place in the county and state where You live. The Federal Arbitration Act, 9 U.S.C. § 1, et seq., will govern and no state, local or other arbitration law will apply. You AGREE AND UNDERSTAND THAT this Arbitration provision means that You give up Your right to go to court on any Claim covered by this provision. You also agree that any Arbitration proceeding will only consider Your Claims. Claims by, or on behalf of, other individuals will not be arbitrated in any proceeding that is considering Your Claims. Please refer to the Special State Disclosure of this Service Contract for any added requirements in Your state. In the event this Arbitration provision is not approved by the appropriate state regulatory agency, and/or is stricken, severed, or otherwise deemed unenforceable by a court of competent jurisdiction, You and We specifically agree to waive and forever give up the right to a trial by jury. Instead, in the event any litigation arises between You and Us, any such lawsuit will be tried before a judge, and a jury will not be impaneled or struck. The Dealer Warranty / Service Contract specifically identifies the dealer as follows: CAM-L-000221-23 03/27/2023 5:17:55 PM Pg5of11 Trans ID: LCV20231043642 DEALER: Refers to the party who sold You this Service Contract. Please see the box labeled "Dealer Name" on the Registration Page for Your Dealer's contact information. The “Dealer” is specified on the first page of the Dealer Warranty / Service Contract as “Auto Concepts,” which is Auto Concepts, Incorporated — the “dealer” defendant named in the Complaint. Plaintiffs Complaint in this action is based upon alleged breaches of warranty — that is, the Dealer Warranty / Service Contract sold by the dealer as part of the sale of the vehicle. The term, “warranty” and related statutes appear at least 40 times in the Complaint. See, e.g., p. 3 Js “R” and “T”; page 9 Js 34, 35 and 36; p. 10 §s 38 and 41; pp. 32-33 §s190; p. 35 196; p, 39 § 203; p. 56 9251;p. 58 4 158. The substance of plaintiff's claims for breach of warranty are alleged at pp. 12 to 15. at Js 50 through 88; some 39 paragraphs. In sum: the dealer sold and plaintiff purchased the vehicle with a Dealer Warranty, which was the “Service Contract.” The Warranty / Service Contract was an integral part of the transaction between the dealer and the plaintiff. It was not a separate transaction. Plaintiff received and signed the Buyer Guide specifying the Dealer Warranty, as well as the Dealer Warranty / Service Contract itself. Plaintiff asserts claims for breach of the Dealer Warranty / Service Contract. Plaintiff's claims are subject to arbitration under the terms of Dealer Warranty / Service Contract. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg6of11 Trans ID: LCV20231043642 LEGAL ARGUMENT POINT I THIS COURT DECIDES THE THRESHOLD QUESTION OF ARBITRABILITY There is no dispute as to this proposition of law. The first “Point” of the brief for plaintiff appears to erect a “straw man” by discussing it. The defendants’ Motion seeks a determination that the dispute be referred to arbitration as provided by the governing contract documents — including without limitation the Buyer’s Guide that plaintiff received and signed. It beggars the imagination to see that plaintiff now claims the Buyer’s Guide did not exist, and that she never saw it. The defense has produced a copy of this document, signed by the plaintiff. Gallo Reply, Exhibit 2. The defense reserves the right to apply for sanctions pursuant to R. 4:46-5(b). It is also troubling that the Complaint alleged only: 40. Upon information and belief, at time of sale, defendants failed to display a buyers guide in the window of the vehicle or anywhere on the vehicle or in close proximity thereto and failed to give any such buyers guide to plaintiffs. ek 193. Upon information and belief, at time of sale, there was no buyers guide displayed in the window of the vehicle, on the body of the vehicle or in close proximity to the vehicle or at the main entrance(s) to the business premises where the vehicle was displayed and defendants never gave plaintiffs any buyers guide for the vehicle. [emphases added] Whose “information and belief’ does the Complaint rely upon? That of counsel? Plaintiffs Certification states that she only provided counsel with the “Buyers Order” and the “Vehicle Service Contract.” Certification of Litigant, § 3. She did not provide counsel with the Buyer’s Guide that bears her signature. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg7of11 Trans ID: LCV20231043642 Plaintiff belatedly asserts, in opposition to this Motion, that there was no “Buyer’s Guide” and that she never received one. Certification of Litigant, { 8. This is flatly contradicted and disproven by the Buyer’s Guide that she received and signed — but did not provide to her attorneys. In { 9, plaintiff retreats and prevaricates by claiming that she “never saw” a Buyer’s Guide. This is likewise disproven, as a documentary fact, by the Buyer’s Guide she received and signed. That she now claims not to recall seeing it does not mean that it did not exist. In { 12, plaintiff asserts that she “never bought any service contract from the dealer. The Service Contract itself, which she signed, specifically identifies the “Dealer” as follows: DEALER: Refers to the party who sold You this Service Contract. Please see the box labeled "Dealer Name" on the Registration Page for Your Dealer's contact information. The first page of the Service Contract identifies Auto Concepts, Incorporated as, in haec verba, the “Dealer ... who sold You (plaintiff) this Service Contract.” We do not concede that there is a bona fide question of fact as to the documents that plaintiff signed. If, however, plaintiff seriously claims that her signatures are forgeries or the like, then we welcome a hearing at which Mr. Gallo and others would testify as to the authenticity of the documents — the Buyer’s Guide, the Service Contract, and the other documents plaintiff signed incident to the purchase of the vehicle. The defense would certainly pursue its rights under R. 4:46-5(b) when, as seems inevitable, plaintiff's Certification is proven to have been false. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg 8of11 Trans ID: LCV20231043642 POINT II THE DEALER WARRANTY / SERVICE CONTRACT IS SUPPORTED BY CONSIDERATION Plaintiffs opposition to the defense Motion, and plaintiffs Crossmotion, are erected upon a foundation of sand. Plaintiff signed the Buyer’s Guide. Plaintiff also signed the Service Contract. The Service Contract — being the Dealer Warranty — was not a separate transaction. The consideration for the Service Contract was the purchase price of the vehicle. These were not two separate transactions. Indeed, the Buyer’s Guide stated that the vehicle was sold with a Dealer Warranty — specified in the Buyer’s Guide as the Service Contract, which plaintiff also signed. The Dealer is specifically identified in the Service Contract as the party from which plaintiff purchased the Service Contract. The Buyer’s Guide confirmed that there was no separate service contract on offer for the vehicle, and no separate charge for such a contract. Again, as stated in the contract documents and confirmed by Mr. Gallo’s Reply Certification, the cost of the Service Contract (as the Dealer Warranty) was included in the price of the vehicle. The provision of the Dealer Warranty / Service was not a gift to the plaintiff. It was bought and paid for as part of the purchase price of the vehicle. This was the basis on which the vehicle was offered for sale. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg9of11 Trans ID: LCV20231043642 POINT II THE DEFENSE MOTION IS NOT BASED UPON A MISTAKE OR OMISSION IN THE PLEADING The defense Motion is for Dismissal and referral to arbitration. The defense does not argue that the Complaint is flawed in itself. Instead, the parties’ contract documents provide for mandatory arbitration — under the applicable Dealer’s Warranty / Service Contract which plaintiff signed and accepted, as designated by the Buyer’s Guide that plaintiff also signed and accepted. Repleading or amendment of the Complaint would not address the basis for the Motion. Put colloquially, it is not what the Complaint failed to say, but the governing documents that plaintiff's Complaint ignores. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg10o0f11 Trans ID: LCV20231043642 POINT IV THE PLAINTIFF’S CROSSMOTION HUST BE DENIED BECAUSE PLAINTIFF HAS NOT EXCLUDED ISSUES OF FACT This is an over-generous description of the Crossmotion. It is based upon assertions that are flatly contrary to fact — such as plaintiffs denial of the Buyer’s Guide that she signed, and her denial that she “bought anything” from the Dealer by way of a warranty under the Service Contract which she signed and which specifically identifies the Dealer as “the party who sold You this Service Contract.” Likewise, plaintiff's Crossmotion is based upon a repudiation of the Complaint itself. In the Complaint, plaintiff asserts against the dealer dozens of alleged violations of the Dealer Warranty / Service Contract. The Complaint invokes a host of warranty-based statutes — over forty (40) allegations including the term, “warranty.” The Complaint makes some thirty-none specific allegations of failure to perform warranty repairs. Now, in opposition to the defense Motion and in support of plaintiff's Crossmotion, plaintiff argues that the Service Contract — which is the Dealer Warranty — does not govern her claims, and that the dealeris a stranger to the very Service Contract she claims was breached. Repudiation of pleadings and denial of the existence of signed contract documents cannot form the basis for a grant of Partial Summary Judgment for plaintiff. CAM-L-000221-23 03/27/2023 5:17:55 PM Pgllof11 Trans ID: LCV20231043642 CONCLUSION The contract documents signed by plaintiff are clear, and binding. The vehicle was sold with a Dealer Warranty, as a single transaction. The Service Contract is that Warranty. The Service Contract contains an arbitration provision that should be enforced. Denying the existence of signed contract documents, or ignoring their provisions, must not deter or delay the agreed-upon arbitration process. For the reasons set forth herein, and in the prior submission on their behalf, the defendants respectfully urge that the Complaint be dismissed in its entirety, with prejudice, pursuant to R. 4:6- 2(e), and the plaintiff be ordered to proceed in the pending arbitration proceeding before the American Arbitration Association under Case Number: 01-23-0000-7958. Respectfully submitted, O’TOOLE SCRIVO, LLC Attorneys for Defendants Auto Concepts, Inc. trading as J&J Auto Outlet, Michael Garro and Joseph Gallo By: /s/ Steven A. Weiner Steven A. Weiner DATED: March 27, 2023 10 CAM-L-000221-23 03/27/2023 5:17:55 PM Pglof2 Trans ID: LCV20231043642 O'TOOLE SCRIVO LLC Steven A. Weiner, Bar ID # 012811975 14 Village Park Road Cedar Grove, NJ 07009 973-239-5700 Fax 973-239-3400 Attorneys for Defendants J&J AUTO OUTLET T/A AUTO CONCEPTS, MICHAEL GARRO, JOE GALLO JULIA ROSE NAWROCKI, INDIVIDUALLY AND SUPERIOR COURT OF NEW JERSEY ON BEHALF OF ALL OTHERS SIMILARLY LAW DIVISION: CAMDEN COUNTY SITUATED, Docket No.: CAM-L-221-23 Plaintiff, CIVIL ACTION vs. J&J AUTO OUTLET T-A AUTO CONCEPTS, REPLY CERTIFICATION OF JOE MICHAEL GARRO, JOE GALLO AND JOHN GALLO IN FURTHER SUPPORT OF DOES 1-10, MOTION TO DISMISS COMPLAINT Defendant(s) AND IN OPPOSITION TO CROSSMOTION Joe Gallo, of full age, hereby certifies and says: 1 Iam a principal of AUTO CONCEPTS, INC. (“Auto Concepts”) which trades as J&J AUTO OUTLET (“J&J”) — collectively, the “Dealer”. As such, | am a custodian the business records referred to in this Certification. I am also named personally as a defendant. oi2. I am familiar the documents relating to the transaction with Plaintiff. 3. Exhibit 1 is a copy of a document entitled, “Tips on Buying a Used Car” prepared and published by the New Jersey Division of Consumer Affairs. I have highlighted the paragraph describing the “Buyer’s Guide.” 4, Exhibit 2 is a copy of the Buyer’s Guide for plaintiff's purchase of the vehicle involved in this action. On the attached copy, I have circled the heading “Buyer’s Guide.” and also the signature of plaintiff Julia Nawrocki. CAM-L-000221-23 03/27/2023 5:17:55 PM Pg2of2 Trans ID: LCV20231043642 5. The Buyer’s Guide was posted in plain view on the vehicle purchased by Ms: Nawrocki. She was given a copy of this document at the time of sale 6. Exhibit 3 comprises several other documents signed by plaintiff Julia Nawrocki when she purchased the vehicle: ° New Jersey Motor Vehicle Commission Universal Title Application Odometer Disclosure Statement Buyer’s Order Sale Receipt Contract Registration Page Notarized Power of Attorney for transferring title and registration of the vehicle e New Jersey Motor Vehicle Commission Application for Registration On each of these, I have circled the signature of plaintiff Julia Nawrocki 7. The Dealer’s Warranty was part of the same transaction in which Ms. Nawrocki purchased the vehicle and is the same warranty referenced on the Buyer’s Guide (copy attached). 8. The Vehicle purchased by Ms. Nawrocki came with a Dealer Warranty (see attached . ‘Buyers Guide”) 9. The cost of the Service Contract, as shown on the Contract Registration Page, was included in the “Selling Price” of $19,995.00 (see Buyer’s Order - copy attached) 10. The “Dealer” is a party to the Service Contract that Ms. Nawrocki purchased. I certify that the foregoing statements made by me is true. | ‘am aware that if the foregoing statements made by me is willfully false, 1 am subject to punishment, Chaat Joe Gallo ” ALE Dated: March 23, 2023 CAM-L-000221-23 03/27/2023 5:17:55 PM Pglof2 Trans ID: LCV20231043642 EXHIBIT 1— CAM-L-000221-23 03/27/2023 5:17:55 PM Pg2of2 Trans ID: LCV20231043642 Tips on Buying a >») Used Car DZ consumer brief” The purchase of a used car can be a high-cost THE USED CAR BUYER'S GUIDE consumer transaction. Here is what you should know Look for the Buyer’sGi | the ind Fc ehicle before making your purchase. you're consi ring ecrihies equir¢ THE USED CAR LENION LAW posted i view sale, The gui nforms th aL abou Is f the Ifa New Jersey dealer sells you a used car that is defective, ‘warrant if one exists, ‘if the | “AS- ”» you mar be eligible for relief under the Used Car Lemon h Law. T! he law requires the dealer to provide a limiced Cars sold “AS-IS” do not come with any warranry, either expressed or implied. The guide will disclose if there is any warranty if the car is — not more than seven (7) years old; remaining manufacturer's warranty on the vehicle, and ifan has less than 100,000 miles; the price is over $3,000; and/ extended service contract is availabl co} F the guide or the car has not been declared a total Joss by an insurance should be given to you at the time of purchase. company. If the car has 60,000 miles on its odometer and the consumer wishes to waive the warranty to negotiate a FINDING THE BEST PRICE better price, che consumer must sign a form that he/she is You should always shop around and negotiate for the best buying che car withouc a warranty. The warranty covers price. Visit several dealerships and don’t be in a hurry. certain components of the engine, transmission and the Used car pricing guides may be found at your local library, front—_ or rear-wheel drive. If you have experienced three bookstore or even online. A current guide will tell you the (3) repair attempts on a covered item within the dealer's used car's retail or trade-in value. You may also be able to warranty period, ou may qualify fora Lemon Law hearing. fi The duration o} the dealer's warranty to which you are find a good deal from ¢ privare seller, but keep in mind thac those cars do not come with any warranty and are not enticled depends on the car's mileage at the time of sale. subject to the Used Car Lemon Law. 3 See the information below. fa Vehicle Mileage Duration of Dealer Warranty Continued Less than 24,000 miles. 90 days or 3,000 miles 24,000 miles to 60,000 miles. 60 days or 2,000 miles ciesa Roprasentatn} (Signature oF Co-Buyor) CAM-L-000221-23 03/27/2023 5:17:55 PM Pg5of8 Trans ID: LCV20231043642 AUTO CONCCPTS 220 £ EVESHAM ROAD sy GLENDORA, N* OB023 | Merchant 10: (572 Term Ws WOOL Store Il: GOU1 Ref tH: G862 Sale AXXKANXXXXAN2488 VISA Entry Hethod: Chip Total: § 2,000.00 09/20/22 17:00:07 Inv ts 000002 Appr Code: 084930 Transaction ID: 582263756071885 Apprvd: Online Batchi: 600067 CAPITAL ONE VISA AID: 40008008031010 TSI: £806 TR: 6000008000 I agree to pay above total amount according to ca rd issuer ayreenen reement if credit voucher) AWROCK1/JULIA Nerchant Copy CAM-L-000221-23 03/27/2023 5:17:55 PM Pg6of8 Trans ID: LCV20231043642 +f = Bs yy tat a 1 eeHS Ee Eges pecCHSTRA 4 fie om Hi ON] os oe a, a 1 re i ay cee a i of = sie 56 Wy A a. a _— ae a ss a 1 ct LING} a . re ee omen cio ste i |. nee a Rn —— at Onn uy a a —- Someta — _ - 1H Sr is oc a. — — a a hen Bec Teh Ve —~- _——. _ ad ————- tiesto .. — mee 1g: a ae oe ve va Prclerred 2 manils. i000 sue vanes — In ee 7 ry Aven Options Engng Transmssion Adi eou Cy ve ide 4 teat on ee" alenna oa dation Period Aan os in 60.00 Days and 1000 Miles USDEEL a thie ares, a Seen ga we QV AI-W sel 1 C1 esut i en 1 it cic ii . (Sut to z surcivany i dis ang Gaskets ai rnctesay hts noni Tr ype sar ste = estat —— —— wi Contracts expire Ui itl We et “i te A ye ite jase Vale (SCPD) For the Tern § nat 4 j val a wee woe ai enace Contract Validalio Penion serage under this Con bean on ahaine ser i i f be Pare ase t! ve 'D). Ithe SCPD 1s more than te iOya Ine ai in achne fh wig parls and labor benefitsare subjectte ties vith ot rai 10 a tt i et Sh eaceeeerraitia a closures Purchase ot this Sr AS sat 1 a You have the right te easter tn 4 " er pte THE CONTRACT REGISTRATION DA. Ante fae WIE EC AGT E tine ac ENMENT £ MOU ARE PROVIDER. NO OTHER GUC! WENT ARE | Anita an OMIDED isu IMiKISTRAT UROR PROV Your Contrar ‘olan: vee in abio ¢ ti he ton Plnae the DIREAION iN its, mired wei the Wi nt te ites 8 4 Woeti gh are allecind litional Disclosures: shinyton Residents are raquired to ini al). Provideris United Service Protection Corpor Betenst nL " ay whericen Bankers Insurance Compan: I Fleita a Wise 4 ih WE a iicah Bankers Insurance Company. of Florida a i i by wth aitializingthe blanks below and gag at Py ahah seit Prop rae ach 4 i ti a teh an aniiie 4 ty tally syne nce Cantract: iS Al HID CONDITION! IS outliny fic 1 oat " 9 nn eoaun ty mi ne oadoe 2 ‘ invtiat IRS EHIGLEIM EAK DOW Low ot ete i ANLCOVERAGE out Coverage i th wit ni 1AT IS NOT COVERED) outlines the conditiur tie in Ge hy are 7H sl NCELLATION OF YOUR RS28 CONTRACT. outtn se i ent rcutlahon Nin. ita implied warranty of morchanlab iy oP the: motor hi nei neck aL Al ce Ca hy Dog De bveit fc ly GOK ofthe jiu se #: molor vehicle from.a provider viho als 6 Sold the mote fovernd hy neyiee ante t dni ‘ada Residents are requirad to initia nowledge and agree that Ihis\ Contact i Ey at srtanaindri claw) fi el ve fice have reviewed or will review its tore ne i 5 neh indi and tat bean fonitn aii i) 1) Pang dis Contarerte ate i ement for arbitration. Initial eee eg ui the thy iit tt ey af eV: hd eerie fication 1 the undersigned) purenay a 7 mea: Toh i ie te PEELS ui av Wine thon SLi i : saaemaT an rage plan selected, par and IANO ‘ i a ony aoe at Aig A aT jens ie 5 and conditions inch ary ipl eS ‘20h we Contract Purchase Date ides a ye teetaia i f- on hs Va iff +) valve a bi tnt a atl L- i eTAM mii oval Adin te VFA pee a Ltt SStrootHa Snag iOna7 font a is his ¢ AeaNit alin beiweonwd Surv thePro)Paichss oe and ath Hn th a){0 Elen io eT a TON a tne. i a ihe Box? “ni Pete csinury, Ft 500 2sMf a6NS AEDT 7 SO Ge eS CAM-L-000221-23 03/27/2023 5:17:55 PM Pg7of8 Trans ID: LCV20231043642 J & J AUTO OUTLET/TA AUTO CONCEPTS 220 EVESHAM RD GLENDORA, NJ 08029 the POWER OF ATTORNEY ie Date: 9/20/22 I constitute and appoint Joseph Gallo ox Michael Garro, my (our) true and lawful attorney-in-fact for the purpose of transferring title and registration, assignment of title, and applications for titles to the above described motor vehicle with full authority to sign on my (our) behalf all papers and documents. and to do all things necessary to this, appointment. Customer: JULIA R NAWROCKI 115 PENN AVE COLLINGSWOOD, NJ 08108 Owner Of: 12 DODGE RAM 1500; GREEN Vin: 1C6RD7LT5CS8329075 Executed on this date: 9/20/22 Signed ee) Af} /E— “ er ined —. TN L STARR BRAND Commiss ion #2448608 Jersey e of New Publlo, Stor NotaryMy.Comm 18910 pexpires August 04, CAM-L-000221-23 03/27/2023 5:17:55 PM Pg 8of8 Trans ID: LCV20231043642 i ane a aud MVC Application for Vehicle Registration Mis orm for & Ne in wh au fl . ei AME FPPLICATION FOR ¥ Cl. TRATION = |1C6RD7LTSCS329075 JULIA R NAWROCK! ma a a ce bys PENN YN AVE ma dene —— 7 preeres | COLLINGSWOOD NJ 06108 aanCAMIDI ae 7 Te Seine Rj. ro | J ~ ot! [8a N09394207956824 | as male ry BLLUE 96 18 198% 2tGE Ys 2tT? an eee a sincere a vr Is} ae = a ate eink is 9 are Daye r— | inte i aie Th 0 arth st 7 Tr @ ne i as, REL pe SSPE Ed tom