Preview
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 2 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : NOTICE OF MOTION TO COMPEL
: PLAINTIFF JAMES BOWERSOCK’S
DEPOSITION
Sir/Madam:
PLEASE TAKE NOTICE that the undersigned attorney for the defendants, Barlow, Buick,
GMC shall move before the Superior Court of New Jersey, Law Division, Camden County,
Camden, New Jersey on Friday, August 27, 2021, for an Order to compel the plaintiff, James
Bowersock to appear for a deposition which is to be conducted on September 14, 2021.
Movant shall rely upon the annexed Certification in support of this Motion.
Pursuant to Rule 1:6-4, I certify that the original of the within motion has been forwarded
to the Clerk of Camden County and upon all respective counsel herein.
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 2 Trans ID: LCV20211813714
A proposed form of Order is attached. Pursuant to Rule 1:6-2(d), the undersigned does not
request oral argument at this time.
Dengler & Lipski
Attorneys for Defendants,
Barlow, Buick, GMC
BY____________________________
Frank A. LaSalvia, Esquire
Dated: August 4, 2021
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 1 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : ORDER
:
THIS MATTER having been opened to the Court upon application of Frank A. LaSalvia,
Esquire of the law firm of Dengler & Lipski, attorneys for defendants, Barlow, Buick, GMC and
the Court having reviewed the moving papers, heard argument of counsel, and good cause having
been shown;
IT IS ON THIS _________ DAY OF ________________________, 2021 ORDERED
that plaintiff James Bowersock is compelled to appear for a deposition which is to be conducted
on September 14, 2021.
_______________________________
J.S.C.
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 2 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : CERTIFICATION OF COUNSEL
:
I, Frank A. LaSalvia, do hereby certify as follows:
1. I am an attorney-at-law of the State of New Jersey and associated with the firm of
Dengler & Lipski and I have been personally entrusted with the handling of the above captioned
matter.
2. This matter arises out of a claim for discrimination and wrongful termination under
the New Jersey Law Against Discrimination.
3. The deposition of the plaintiff has been scheduled on numerous occasions.
4. Plaintiff’s deposition was previously scheduled for February 17, 2021 and June 22
2021. (Ex. “A”, See deposition notices dated December 15, 2020 and May 26, 2021)
5. On June 29, 2021 and July 14, 2021 correspondence was exchanged to reschedule
the plaintiff’s deposition, however plaintiff never responded with a date for the deposition. (Ex.
“B”, Emails dated June 29, 2021 and July 14, 2021).
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 2 Trans ID: LCV20211813714
6. The deposition in this matter is currently scheduled for September 14, 2021.
7. Defendant needs to obtain information regarding the plaintiff’s claim that he was
discriminated and wrongfully terminated.
8. Defendant will be prejudiced if the discovery items are not completed.
9. Answering defendant is not in default of discovery.
10. This Certification is in support of a Motion to Compel the deposition of the plaintiff
for James Bowersock pursuant to 4:23-1.
11. I hereby certify that the foregoing statements made by me are true. I am aware that
if any of the foregoing statements made by me are willfully false, I am subject to punishment.
Dengler & Lipski
Attorneys for Defendants,
Barlow, Buick, GMC
BY____________________________
Frank A. LaSalvia, Esquire
Dated: August 4, 2021
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 1 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : Certification of Service
:
I certify that I electronically filed with the Clerk of Camden County. All other parties will
be electronically served by the court. I certify that the foregoing statements made by me are true.
I am aware that if any of the foregoing statements made by me are willfully false, I am subject to
punishment.
Keith J. Gentes
Malamut & Associates
457 Haddonfield Road
Suite 500
Cherry Hill, NJ 08002
____________________
Sandra J. Fletcher, Paralegal
Dated: August 4, 2021
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 8 Trans ID: LCV20211813714
EXHIBIT A
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 8 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : NOTICE TO TAKE ORAL
: DEPOSITION
TO: Keith J. Gentes, Esquire
Attorney for Plaintiff
PLEASE TAKE NOTICE that in accordance with the Rules of Civil Practice and
Procedure, testimony will be taken by deposition upon oral examination before a Certified
Shorthand Reporter authorized by the laws of the State of New Jersey to administer oaths on
February 17, 2021 at 10:00 a.m. via Zoom with respect to all matters relevant to the subject
matter involved in this action, at which time and place you will please produce the following
person(s) whose testimony is to be taken: JAMES BOWERSOCK
TAKE FURTHER NOTICE that at the same time and place the testimony of the
following persons will also be taken:
Dated: December 15, 2020 DENGLER & LIPSKI
BY: FRANK A. LaSALVIA
Attorney for Defendant
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 3 of 8 Trans ID: LCV20211813714
Frank A. LaSalvia - Attorney ID #: 049101991
DENGLER & LIPSKI
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct Dial: (215) 861-6729
Fax: (215) 861-6737
Attorney for Defendant, Barlow, Buick, GMC
File No. 475785
JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY
Plaintiff(s), : LAW DIVISION
: CAMDEN COUNTY
vs. :
: DOCKET NO. CAM-L-001993-20
BARLOW, BUICK, GMC :
JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION
ABC CORP. 1-10, fictitious entities, :
Defendant(s). : NOTICE TO TAKE ORAL
: DEPOSITION
TO: Keith J. Gentes, Esquire
Attorney for Plaintiff
PLEASE TAKE NOTICE that in accordance with the Rules of Civil Practice and
Procedure, testimony will be taken by deposition upon oral examination before a Certified
Shorthand Reporter authorized by the laws of the State of New Jersey to administer oaths on
June 22, 2021 at 10:00 a.m. via Zoom with respect to all matters relevant to the subject matter
involved in this action, at which time and place you will please produce the following person(s)
whose testimony is to be taken: JAMES BOWERSOCK
TAKE FURTHER NOTICE that at the same time and place the testimony of the
following persons will also be taken:
Dated: May 26, 2021 DENGLER & LIPSKI
BY: FRANK A. LaSALVIA
Attorney for Defendant
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 4 of 8 Trans ID: LCV20211813714
EXHIBIT B
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 5 of 8 Trans ID: LCV20211813714
From: Deborah Calabro
To: SHampton@malamutlaw.com
Subject: Bowersock, James vs. Barlow, Buick, GMC - Deposition
Date: Tuesday, June 29, 2021 9:14:38 AM
Attachments: image001.jpg
image007.jpg
image008.jpg
image009.jpg
image010.jpg
image011.jpg
image012.jpg
image013.jpg
image014.jpg
image015.jpg
Good morning, Sarah,
Mr. LaSalvia is available as follows for depositions in the above matter:
July 26, 27, 29
August 2, 3, 4, 5
Will this be the depositions of all parties?
Let me know which date will work and if you are requesting our client I will check with the
representative to make sure the date is good before we confirm.
Thanks.
Debbie
Deborah R. Calabro
Secretary to Frank A. LaSalvia, James J. Law, Christopher P.
Morgan and Kevin J. Ruane
DENGLER & LIPSKI
Not a Partnership – Employees of Zurich American Insurance
Company
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct: 215-861-6722
Office: 215-861-6700
Fax: 215-861-6737
Email: Deborah.calabro@zurichna.com
**COVID-19 STATEMENT: Please be advised that this document/s and all future documents, until further notice, will be served via
eFile or email to all parties only and will not be served by regular mail due to office closures/remote work and other protocols
enacted to address the spread of COVID-19. Please be further advised that we request that all documents be served via email to the
handling attorney. We may need to follow up in the future for original authorizations as required by the providers or law.
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 6 of 8 Trans ID: LCV20211813714
We continue to be available and will be working remotely during this crisis. Please call or email me at any time. You also may
contact my manager, Danielle Halpin, at danielle.halpin@zurichna.com, if I am unavailable, or to address any other concerns you
may have. **
INTERNAL USE ONLY
From: Sandra Fletcher
Sent: Monday, June 28, 2021 3:54 PM
To: SHampton@malamutlaw.com
Cc: Deborah Calabro
Subject: FW: Bowersock, James vs. Barlow, Buick, GMC - Deposition
Sarah,
I’ve cc’d Frank’s secretary on this email who handles all of his scheduling.
Sandra Fletcher, Sr. Paralegal
Paralegal for Frank LaSalvia, Christopher Morgan and James Law
Dengler & Lipski Not a Partnership-Employees of Zurich American Insurance Company
2000 Market Street, Suite 1100
Philadelphia, PA 19103
O: 215-861-6725
F: 215-861-6737
Email: Sandra.Fletcher@zurichna.com
**COVID-19 STATEMENT: Please be advised that this document/s and all future documents,
until further notice, will be served via eFile or email to all parties only and will not be
served by regular mail due to office closures/remote work and other protocols enacted to
address the spread of COVID-19. Please be further advised that we request that all
documents be served via email to the handling attorney. We may need to follow up in the
future for original authorizations as required by the providers or law.
We continue to be available and will be working remotely during this crisis. Please call or
email me at any time. You also may contact the Managing Attorney Bill Dengler at
bill.dengler@zurichna.com, if I am unavailable, or to address any other concerns you may
have. **
INTERNAL USE ONLY
From: Sarah Hampton
Sent: Monday, June 28, 2021 3:15 PM
To: Sandra Fletcher
Subject: [EXTERNAL] Bowersock, James vs. Barlow, Buick, GMC
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 7 of 8 Trans ID: LCV20211813714
Good Afternoon Sandra,
I wanted to reach out and see when you would be available to have the deposition for the matter
above. Please let me know at your earliest convenience.
Thanks,
Sarah
Sarah Hampton
Paralegal
E: shampton@Malamutlaw.com
O: 856-424-1808
F: 856-424-2032
W: www.MalamutLaw.com
This message and attachment(s) are intended solely for use by the addressee and may contain information that is privileged, confidential
or otherwise exempt from disclosure under applicable law. If you are not the intended recipient or agent thereof responsible for
delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this
communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by
telephone and with a 'reply' message. Thank you for your cooperation.
IRS CIRCULAR 230 DISCLOSURE:
To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this
communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding
penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter
addressed herein.
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 8 of 8 Trans ID: LCV20211813714
From: Deborah Calabro
To: SHampton@malamutlaw.com
Subject: Bowersock v. Barlow, Buick
Date: Wednesday, July 14, 2021 4:51:45 PM
Attachments: image001.jpg
image002.jpg
image003.jpg
image004.jpg
image005.jpg
Hi Sarah,
I am following up on emails from June 29th. I replied to your deposition inquiry. Mr. LaSalvia is still
available as follows:
July 29
August 2, 3, 4
Please let me know which date works for your office and your clients.
Thanks.
Deborah R. Calabro
Secretary to Frank A. LaSalvia, James J. Law, Christopher P.
Morgan and Kevin J. Ruane
DENGLER & LIPSKI
Not a Partnership – Employees of Zurich American Insurance
Company
2000 Market Street, Suite 1100
Philadelphia, PA 19103
Direct: 215-861-6722
Office: 215-861-6700
Fax: 215-861-6737
Email: Deborah.calabro@zurichna.com
**COVID-19 STATEMENT: Please be advised that this document/s and all future documents, until further notice, will be served via
eFile or email to all parties only and will not be served by regular mail due to office closures/remote work and other protocols
enacted to address the spread of COVID-19. Please be further advised that we request that all documents be served via email to the
handling attorney. We may need to follow up in the future for original authorizations as required by the providers or law.
We continue to be available and will be working remotely during this crisis. Please call or email me at any time. You also may
contact my manager, Danielle Halpin, at danielle.halpin@zurichna.com, if I am unavailable, or to address any other concerns you
may have. **
Preview
CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 2 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : NOTICE OF MOTION TO COMPEL : PLAINTIFF JAMES BOWERSOCK’S DEPOSITION Sir/Madam: PLEASE TAKE NOTICE that the undersigned attorney for the defendants, Barlow, Buick, GMC shall move before the Superior Court of New Jersey, Law Division, Camden County, Camden, New Jersey on Friday, August 27, 2021, for an Order to compel the plaintiff, James Bowersock to appear for a deposition which is to be conducted on September 14, 2021. Movant shall rely upon the annexed Certification in support of this Motion. Pursuant to Rule 1:6-4, I certify that the original of the within motion has been forwarded to the Clerk of Camden County and upon all respective counsel herein. CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 2 Trans ID: LCV20211813714 A proposed form of Order is attached. Pursuant to Rule 1:6-2(d), the undersigned does not request oral argument at this time. Dengler & Lipski Attorneys for Defendants, Barlow, Buick, GMC BY____________________________ Frank A. LaSalvia, Esquire Dated: August 4, 2021 CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 1 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : ORDER : THIS MATTER having been opened to the Court upon application of Frank A. LaSalvia, Esquire of the law firm of Dengler & Lipski, attorneys for defendants, Barlow, Buick, GMC and the Court having reviewed the moving papers, heard argument of counsel, and good cause having been shown; IT IS ON THIS _________ DAY OF ________________________, 2021 ORDERED that plaintiff James Bowersock is compelled to appear for a deposition which is to be conducted on September 14, 2021. _______________________________ J.S.C. CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 2 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : CERTIFICATION OF COUNSEL : I, Frank A. LaSalvia, do hereby certify as follows: 1. I am an attorney-at-law of the State of New Jersey and associated with the firm of Dengler & Lipski and I have been personally entrusted with the handling of the above captioned matter. 2. This matter arises out of a claim for discrimination and wrongful termination under the New Jersey Law Against Discrimination. 3. The deposition of the plaintiff has been scheduled on numerous occasions. 4. Plaintiff’s deposition was previously scheduled for February 17, 2021 and June 22 2021. (Ex. “A”, See deposition notices dated December 15, 2020 and May 26, 2021) 5. On June 29, 2021 and July 14, 2021 correspondence was exchanged to reschedule the plaintiff’s deposition, however plaintiff never responded with a date for the deposition. (Ex. “B”, Emails dated June 29, 2021 and July 14, 2021). CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 2 Trans ID: LCV20211813714 6. The deposition in this matter is currently scheduled for September 14, 2021. 7. Defendant needs to obtain information regarding the plaintiff’s claim that he was discriminated and wrongfully terminated. 8. Defendant will be prejudiced if the discovery items are not completed. 9. Answering defendant is not in default of discovery. 10. This Certification is in support of a Motion to Compel the deposition of the plaintiff for James Bowersock pursuant to 4:23-1. 11. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dengler & Lipski Attorneys for Defendants, Barlow, Buick, GMC BY____________________________ Frank A. LaSalvia, Esquire Dated: August 4, 2021 CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 1 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : Certification of Service : I certify that I electronically filed with the Clerk of Camden County. All other parties will be electronically served by the court. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Keith J. Gentes Malamut & Associates 457 Haddonfield Road Suite 500 Cherry Hill, NJ 08002 ____________________ Sandra J. Fletcher, Paralegal Dated: August 4, 2021 CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 1 of 8 Trans ID: LCV20211813714 EXHIBIT A CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 2 of 8 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : NOTICE TO TAKE ORAL : DEPOSITION TO: Keith J. Gentes, Esquire Attorney for Plaintiff PLEASE TAKE NOTICE that in accordance with the Rules of Civil Practice and Procedure, testimony will be taken by deposition upon oral examination before a Certified Shorthand Reporter authorized by the laws of the State of New Jersey to administer oaths on February 17, 2021 at 10:00 a.m. via Zoom with respect to all matters relevant to the subject matter involved in this action, at which time and place you will please produce the following person(s) whose testimony is to be taken: JAMES BOWERSOCK TAKE FURTHER NOTICE that at the same time and place the testimony of the following persons will also be taken: Dated: December 15, 2020 DENGLER & LIPSKI BY: FRANK A. LaSALVIA Attorney for Defendant CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 3 of 8 Trans ID: LCV20211813714 Frank A. LaSalvia - Attorney ID #: 049101991 DENGLER & LIPSKI 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct Dial: (215) 861-6729 Fax: (215) 861-6737 Attorney for Defendant, Barlow, Buick, GMC File No. 475785 JAMES BOWERSOCK, : SUPERIOR COURT OF NEW JERSEY Plaintiff(s), : LAW DIVISION : CAMDEN COUNTY vs. : : DOCKET NO. CAM-L-001993-20 BARLOW, BUICK, GMC : JOHN/JANE DOES 1-10, fictitious person; : CIVIL ACTION ABC CORP. 1-10, fictitious entities, : Defendant(s). : NOTICE TO TAKE ORAL : DEPOSITION TO: Keith J. Gentes, Esquire Attorney for Plaintiff PLEASE TAKE NOTICE that in accordance with the Rules of Civil Practice and Procedure, testimony will be taken by deposition upon oral examination before a Certified Shorthand Reporter authorized by the laws of the State of New Jersey to administer oaths on June 22, 2021 at 10:00 a.m. via Zoom with respect to all matters relevant to the subject matter involved in this action, at which time and place you will please produce the following person(s) whose testimony is to be taken: JAMES BOWERSOCK TAKE FURTHER NOTICE that at the same time and place the testimony of the following persons will also be taken: Dated: May 26, 2021 DENGLER & LIPSKI BY: FRANK A. LaSALVIA Attorney for Defendant CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 4 of 8 Trans ID: LCV20211813714 EXHIBIT B CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 5 of 8 Trans ID: LCV20211813714 From: Deborah Calabro To: SHampton@malamutlaw.com Subject: Bowersock, James vs. Barlow, Buick, GMC - Deposition Date: Tuesday, June 29, 2021 9:14:38 AM Attachments: image001.jpg image007.jpg image008.jpg image009.jpg image010.jpg image011.jpg image012.jpg image013.jpg image014.jpg image015.jpg Good morning, Sarah, Mr. LaSalvia is available as follows for depositions in the above matter: July 26, 27, 29 August 2, 3, 4, 5 Will this be the depositions of all parties? Let me know which date will work and if you are requesting our client I will check with the representative to make sure the date is good before we confirm. Thanks. Debbie Deborah R. Calabro Secretary to Frank A. LaSalvia, James J. Law, Christopher P. Morgan and Kevin J. Ruane DENGLER & LIPSKI Not a Partnership – Employees of Zurich American Insurance Company 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct: 215-861-6722 Office: 215-861-6700 Fax: 215-861-6737 Email: Deborah.calabro@zurichna.com **COVID-19 STATEMENT: Please be advised that this document/s and all future documents, until further notice, will be served via eFile or email to all parties only and will not be served by regular mail due to office closures/remote work and other protocols enacted to address the spread of COVID-19. Please be further advised that we request that all documents be served via email to the handling attorney. We may need to follow up in the future for original authorizations as required by the providers or law. CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 6 of 8 Trans ID: LCV20211813714 We continue to be available and will be working remotely during this crisis. Please call or email me at any time. You also may contact my manager, Danielle Halpin, at danielle.halpin@zurichna.com, if I am unavailable, or to address any other concerns you may have. ** INTERNAL USE ONLY From: Sandra Fletcher Sent: Monday, June 28, 2021 3:54 PM To: SHampton@malamutlaw.com Cc: Deborah Calabro Subject: FW: Bowersock, James vs. Barlow, Buick, GMC - Deposition Sarah, I’ve cc’d Frank’s secretary on this email who handles all of his scheduling. Sandra Fletcher, Sr. Paralegal Paralegal for Frank LaSalvia, Christopher Morgan and James Law Dengler & Lipski Not a Partnership-Employees of Zurich American Insurance Company 2000 Market Street, Suite 1100 Philadelphia, PA 19103 O: 215-861-6725 F: 215-861-6737 Email: Sandra.Fletcher@zurichna.com **COVID-19 STATEMENT: Please be advised that this document/s and all future documents, until further notice, will be served via eFile or email to all parties only and will not be served by regular mail due to office closures/remote work and other protocols enacted to address the spread of COVID-19. Please be further advised that we request that all documents be served via email to the handling attorney. We may need to follow up in the future for original authorizations as required by the providers or law. We continue to be available and will be working remotely during this crisis. Please call or email me at any time. You also may contact the Managing Attorney Bill Dengler at bill.dengler@zurichna.com, if I am unavailable, or to address any other concerns you may have. ** INTERNAL USE ONLY From: Sarah Hampton Sent: Monday, June 28, 2021 3:15 PM To: Sandra Fletcher Subject: [EXTERNAL] Bowersock, James vs. Barlow, Buick, GMC CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 7 of 8 Trans ID: LCV20211813714 Good Afternoon Sandra, I wanted to reach out and see when you would be available to have the deposition for the matter above. Please let me know at your earliest convenience. Thanks, Sarah Sarah Hampton Paralegal E: shampton@Malamutlaw.com O: 856-424-1808 F: 856-424-2032 W: www.MalamutLaw.com This message and attachment(s) are intended solely for use by the addressee and may contain information that is privileged, confidential or otherwise exempt from disclosure under applicable law. If you are not the intended recipient or agent thereof responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by telephone and with a 'reply' message. Thank you for your cooperation. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. CAM-L-001993-20 08/04/2021 10:01:29 AM Pg 8 of 8 Trans ID: LCV20211813714 From: Deborah Calabro To: SHampton@malamutlaw.com Subject: Bowersock v. Barlow, Buick Date: Wednesday, July 14, 2021 4:51:45 PM Attachments: image001.jpg image002.jpg image003.jpg image004.jpg image005.jpg Hi Sarah, I am following up on emails from June 29th. I replied to your deposition inquiry. Mr. LaSalvia is still available as follows: July 29 August 2, 3, 4 Please let me know which date works for your office and your clients. Thanks. Deborah R. Calabro Secretary to Frank A. LaSalvia, James J. Law, Christopher P. Morgan and Kevin J. Ruane DENGLER & LIPSKI Not a Partnership – Employees of Zurich American Insurance Company 2000 Market Street, Suite 1100 Philadelphia, PA 19103 Direct: 215-861-6722 Office: 215-861-6700 Fax: 215-861-6737 Email: Deborah.calabro@zurichna.com **COVID-19 STATEMENT: Please be advised that this document/s and all future documents, until further notice, will be served via eFile or email to all parties only and will not be served by regular mail due to office closures/remote work and other protocols enacted to address the spread of COVID-19. Please be further advised that we request that all documents be served via email to the handling attorney. We may need to follow up in the future for original authorizations as required by the providers or law. We continue to be available and will be working remotely during this crisis. Please call or email me at any time. You also may contact my manager, Danielle Halpin, at danielle.halpin@zurichna.com, if I am unavailable, or to address any other concerns you may have. **