Preview
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949
ARCHER & GREINER
A Professional Corporation
1025 Laurel Oak Road
Voorhees, NJ 08043
(856) 795-2121
Attorneys for Plaintiff
BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991))
TRACY SNYDER SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
Plaintiff, CAMDEN COUNTY
v.
DOCKET NO.: CAM-L-002505-22
GONDUL TRUCKING, INC., JHOBANY
CRUZ, BURLINGTON COUNTY SPRING
SHOP, LLC, JOHN DOES 1-10, and ABC NOTICE OF MOTION TO COMPEL
DEPOSITIONS PURSUANT
ENTITIES 1-5
TO R. 4:23-2 and R. 4:23-4
Defendants.
PLEASE TAKE NOTICE that on December 1, 2023 at 9:00 a.m., or as soon thereafter as
counsel may be heard, Archer & Greiner, P.C., attorneys for Plaintiff in the above-captioned matter
pursuant to R. 4:23-2 and R. 4:23-4 shall move before the Court located at Camden County Superior
Court, Hall of Justice, 101 S. 5th Street, Camden, New Jersey 08103 for an Order Compelling the
Depositions of a Corporate Representative of Defendant Gondul Trucking, Inc and Huseyin Ozboy,
Registered Agent for Gondul Trucking, Inc.
PLEASE TAKE FURTHER NOTICE that in support of this application, the undersigned will
rely upon the attached Certification of William J. O’Kane, Jr. Esquire.
PLEASE TAKE FURTHER NOTICE that pursuant to R.1:6-2, Plaintiff hereby waives oral
argument and consents to disposition on the papers; and
PLEASE TAKE FURTHER NOTICE, that there are currently no arbitration or trial dates as
discovery is scheduled to end on December 18, 2023.
The moving party has submitted a proposed form of Order
ARCHER & GREINER
A Professional Corporation
Attorneys for Plaintiff
/s/ William J. O’Kane, Jr.
WILLIAM J. O’KANE, JR.
Date: November 15, 2023
SNY041-00701-228040202 v1
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949
ARCHER & GREINER
A Professional Corporation
1025 Laurel Oak Road
Voorhees, NJ 08043
(856) 795-2121
Attorneys for Plaintiff
BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991)
______________________________________ _______________________________________
TRACY SNYDER SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
Plaintiff, CAMDEN COUNTY
v. DOCKET NO.: CAM-L-002505-22
GONDUL TRUCKING, INC., JHOBANY
CRUZ, BURLINGTON COUNTY SPRING ORDER TO COMPEL DEPOSITIONS
SHOP, LLC, JOHN DOES 1-10, and ABC PURSUANT TO R. 4:23-2 and R. 4:23-4
ENTITIES 1-5
Defendants.
THIS MATTER having come before the Court upon Plaintiff’s Motion to Compel, by
and through her attorneys, Archer & Greiner, A Professional Corporation, William J. O’Kane,
Jr., Esquire appearing; and the Court having reviewed the Motion and any opposition, including
any certifications submitted therewith, and having heard arguments of counsel (if any), and for
good cause shown,
IT IS, on this _______ day of _____________________, 2023, ORDERED as follows:
1. Plaintiff’s Motion to Compel Depositions is GRANTED.
2. Defendant Gondul Trucking, Inc is compelled to produce for depositions a
corporate representative along with Huseyin Ozboy no later than December 15, 2023.
IT IS FURTHER ORDERED that a copy of this Order shall be served upon all counsel
of record within seven (7) days of the date hereof.
___________________________
J.S.C.
[ ] Opposed
[ ] Unopposed
228040204 v1
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 3 Trans ID: LCV20233377949
ARCHER & GREINER
A Professional Corporation
1025 Laurel Oak Road
Voorhees, NJ 08043
(856) 795-2121
Attorneys for Plaintiff
BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991)
______________________________________ _______________________________________
TRACY SNYDER SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
Plaintiff, CAMDEN COUNTY
v. DOCKET NO.: CAM-L-002505-22
GONDUL TRUCKING, INC., JHOBANY
CRUZ, BURLINGTON COUNTY SPRING CERTIFICATION OF WILLIAM J.
SHOP, LLC, JOHN DOES 1-10, and ABC O’KANE, JR., ESQUIRE IN SUPPORT OF
ENTITIES 1-5 MOTION TO COMPEL DEPOSITIONS
PURSUANT TO R. 4:23-2 and R. 4:23-4
Defendants.
I, WILLIAM J. O’KANE, JR. of full age, hereby certify as follows:
1. I am an attorney-at-law licensed to practice in the State of New Jersey and a
partner in the law firm of Archer & Greiner, P.C., located at 1025 Laurel Oak Road, Voorhees,
New Jersey 08043, counsel for the Plaintiff, Tracy Snyder, in the above-captioned matter.
2. As such, I am fully familiar with this matter and the facts set forth herein.
3. This is an automobile personal injury matter brought by Tracy Snyder against the
Defendants in a Complaint filed on September 23, 2022 and an Amended Complaint filed on
June 23, 2023.
4. Plaintiff’s counsel sent deposition notices to counsel for the Defendant, Gondul
Trucking, Inc. on September 26, 2023. The deposition notices were for a corporate
representative of Gondul Trucking, Inc. and its Registered Agent, Huseyin Ozboy to take place
on October 17, 2023.
5. On October 2, 2023, counsel for the Defendant, Gondul Trucking, Inc. responded
to the deposition notices advising the Huseyin Ozboy was in Turkey caring for a relative and that
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 2 of 3 Trans ID: LCV20233377949
Ali Taz, the nephew of Huseyin Ozboy, would be produced as the corporate representative for
Defendant, Gondul Trucking, Inc. on October 17, 2023 and that Huseyin Ozboy would have to
be rescheduled for a later date.
6. On October 16, 2023, counsel for the Defendant, Gondul Trucking, Inc. notified
Plaintiff’s counsel via email that the October 17, 2023 deposition needed to be canceled and
rescheduled.
7. On November 3, 2023, Plaintiff’s counsel sent via email new dates to counsel for
Defendant, Gondul Trucking, Inc. in an attempt to reschedule the depositions.
8. On November 6, 2023, Plaintiff’s counsel sent via email new dates to counsel for
Defendant, Gondul Trucking, Inc. in an attempt to reschedule the depositions.
9. On November 6, 2023, counsel for the Defendant, Gondul trucking, Inc.
responded via email that he was trying to confirm new dates with his client for the depositions.
10. On November 9, 2023, Plaintiff’s counsel left a voice message and sent via email
new dates to counsel for Defendant, Gondul Trucking, Inc. in another attempt to reschedule the
depositions.
11. As of the filing of this Motion, Plaintiff has yet to receive a response from
Defendant Gondul Trucking Inc. with a confirmed date to take the deposition. These depositions
are necessary to make this case trial ready.
12. Plaintiff respectfully requests an Order of this Court compelling Defendant,
Gondul Trucking Inc.’s corporate representative and Huseyin Ozboy.
13. The matter is not currently listed for a trial or arbitration.
14. Plaintiff has provided all written discovery to Defendants as well as Plaintiff’s
deposition.
15. The current discovery end date is December 18, 2023.
2
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 3 of 3 Trans ID: LCV20233377949
16. A proposed form or Order is attached.
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.
_
WILLIAM J. O’KANE, JR, ESQUIRE
Date: November 15, 2023
228040203 v1
3
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949
ARCHER & GREINER
A Professional Corporation
1025 Laurel Oak Road
Voorhees, NJ 08043
(856) 795-2121
Attorneys for Plaintiff
BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991)
______________________________________ _______________________________________
TRACY SNYDER SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
Plaintiff, CAMDEN COUNTY
v. DOCKET NO.: CAM-L-002505-22
GONDUL TRUCKING, INC., JHOBANY
CRUZ, BURLINGTON COUNTY SPRING CERTIFICATION OF SERVICE
SHOP, LLC, JOHN DOES 1-10, and ABC OF MOTION TO COMPEL
ENTITIES 1-5
Defendants.
CERTIFICATION OF PROOF OF SERVICE
I, the undersigned, of the law firm of Archer & Greiner, P.C., attorneys for Plaintiff,
Tracy Snyder in the above-entitled action, do hereby certify that On November 15, 2023, a copy
of the Notice of Motion to Compel, Certification in Support of Motion, and proposed form of
Order and in compliance with Rule 1:6-4, the original of the within has been E-filed with the
Motion's Clerk of Camden County Superior Court, and copies have been served upon the
following via the E-filing system to the following:
Matthew Toto, Esquire
TRAUB LIEBERMAN
322 Highway 35 3rd Floor
Red Bank, NJ 07701
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.
WILLIAM J. O’KANE, JR., ESQUIRE
Date: November 15, 2023
228040215 v1
Preview
CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949 ARCHER & GREINER A Professional Corporation 1025 Laurel Oak Road Voorhees, NJ 08043 (856) 795-2121 Attorneys for Plaintiff BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991)) TRACY SNYDER SUPERIOR COURT OF NEW JERSEY LAW DIVISION Plaintiff, CAMDEN COUNTY v. DOCKET NO.: CAM-L-002505-22 GONDUL TRUCKING, INC., JHOBANY CRUZ, BURLINGTON COUNTY SPRING SHOP, LLC, JOHN DOES 1-10, and ABC NOTICE OF MOTION TO COMPEL DEPOSITIONS PURSUANT ENTITIES 1-5 TO R. 4:23-2 and R. 4:23-4 Defendants. PLEASE TAKE NOTICE that on December 1, 2023 at 9:00 a.m., or as soon thereafter as counsel may be heard, Archer & Greiner, P.C., attorneys for Plaintiff in the above-captioned matter pursuant to R. 4:23-2 and R. 4:23-4 shall move before the Court located at Camden County Superior Court, Hall of Justice, 101 S. 5th Street, Camden, New Jersey 08103 for an Order Compelling the Depositions of a Corporate Representative of Defendant Gondul Trucking, Inc and Huseyin Ozboy, Registered Agent for Gondul Trucking, Inc. PLEASE TAKE FURTHER NOTICE that in support of this application, the undersigned will rely upon the attached Certification of William J. O’Kane, Jr. Esquire. PLEASE TAKE FURTHER NOTICE that pursuant to R.1:6-2, Plaintiff hereby waives oral argument and consents to disposition on the papers; and PLEASE TAKE FURTHER NOTICE, that there are currently no arbitration or trial dates as discovery is scheduled to end on December 18, 2023. The moving party has submitted a proposed form of Order ARCHER & GREINER A Professional Corporation Attorneys for Plaintiff /s/ William J. O’Kane, Jr. WILLIAM J. O’KANE, JR. Date: November 15, 2023 SNY041-00701-228040202 v1 CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949 ARCHER & GREINER A Professional Corporation 1025 Laurel Oak Road Voorhees, NJ 08043 (856) 795-2121 Attorneys for Plaintiff BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991) ______________________________________ _______________________________________ TRACY SNYDER SUPERIOR COURT OF NEW JERSEY LAW DIVISION Plaintiff, CAMDEN COUNTY v. DOCKET NO.: CAM-L-002505-22 GONDUL TRUCKING, INC., JHOBANY CRUZ, BURLINGTON COUNTY SPRING ORDER TO COMPEL DEPOSITIONS SHOP, LLC, JOHN DOES 1-10, and ABC PURSUANT TO R. 4:23-2 and R. 4:23-4 ENTITIES 1-5 Defendants. THIS MATTER having come before the Court upon Plaintiff’s Motion to Compel, by and through her attorneys, Archer & Greiner, A Professional Corporation, William J. O’Kane, Jr., Esquire appearing; and the Court having reviewed the Motion and any opposition, including any certifications submitted therewith, and having heard arguments of counsel (if any), and for good cause shown, IT IS, on this _______ day of _____________________, 2023, ORDERED as follows: 1. Plaintiff’s Motion to Compel Depositions is GRANTED. 2. Defendant Gondul Trucking, Inc is compelled to produce for depositions a corporate representative along with Huseyin Ozboy no later than December 15, 2023. IT IS FURTHER ORDERED that a copy of this Order shall be served upon all counsel of record within seven (7) days of the date hereof. ___________________________ J.S.C. [ ] Opposed [ ] Unopposed 228040204 v1 CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 3 Trans ID: LCV20233377949 ARCHER & GREINER A Professional Corporation 1025 Laurel Oak Road Voorhees, NJ 08043 (856) 795-2121 Attorneys for Plaintiff BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991) ______________________________________ _______________________________________ TRACY SNYDER SUPERIOR COURT OF NEW JERSEY LAW DIVISION Plaintiff, CAMDEN COUNTY v. DOCKET NO.: CAM-L-002505-22 GONDUL TRUCKING, INC., JHOBANY CRUZ, BURLINGTON COUNTY SPRING CERTIFICATION OF WILLIAM J. SHOP, LLC, JOHN DOES 1-10, and ABC O’KANE, JR., ESQUIRE IN SUPPORT OF ENTITIES 1-5 MOTION TO COMPEL DEPOSITIONS PURSUANT TO R. 4:23-2 and R. 4:23-4 Defendants. I, WILLIAM J. O’KANE, JR. of full age, hereby certify as follows: 1. I am an attorney-at-law licensed to practice in the State of New Jersey and a partner in the law firm of Archer & Greiner, P.C., located at 1025 Laurel Oak Road, Voorhees, New Jersey 08043, counsel for the Plaintiff, Tracy Snyder, in the above-captioned matter. 2. As such, I am fully familiar with this matter and the facts set forth herein. 3. This is an automobile personal injury matter brought by Tracy Snyder against the Defendants in a Complaint filed on September 23, 2022 and an Amended Complaint filed on June 23, 2023. 4. Plaintiff’s counsel sent deposition notices to counsel for the Defendant, Gondul Trucking, Inc. on September 26, 2023. The deposition notices were for a corporate representative of Gondul Trucking, Inc. and its Registered Agent, Huseyin Ozboy to take place on October 17, 2023. 5. On October 2, 2023, counsel for the Defendant, Gondul Trucking, Inc. responded to the deposition notices advising the Huseyin Ozboy was in Turkey caring for a relative and that CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 2 of 3 Trans ID: LCV20233377949 Ali Taz, the nephew of Huseyin Ozboy, would be produced as the corporate representative for Defendant, Gondul Trucking, Inc. on October 17, 2023 and that Huseyin Ozboy would have to be rescheduled for a later date. 6. On October 16, 2023, counsel for the Defendant, Gondul Trucking, Inc. notified Plaintiff’s counsel via email that the October 17, 2023 deposition needed to be canceled and rescheduled. 7. On November 3, 2023, Plaintiff’s counsel sent via email new dates to counsel for Defendant, Gondul Trucking, Inc. in an attempt to reschedule the depositions. 8. On November 6, 2023, Plaintiff’s counsel sent via email new dates to counsel for Defendant, Gondul Trucking, Inc. in an attempt to reschedule the depositions. 9. On November 6, 2023, counsel for the Defendant, Gondul trucking, Inc. responded via email that he was trying to confirm new dates with his client for the depositions. 10. On November 9, 2023, Plaintiff’s counsel left a voice message and sent via email new dates to counsel for Defendant, Gondul Trucking, Inc. in another attempt to reschedule the depositions. 11. As of the filing of this Motion, Plaintiff has yet to receive a response from Defendant Gondul Trucking Inc. with a confirmed date to take the deposition. These depositions are necessary to make this case trial ready. 12. Plaintiff respectfully requests an Order of this Court compelling Defendant, Gondul Trucking Inc.’s corporate representative and Huseyin Ozboy. 13. The matter is not currently listed for a trial or arbitration. 14. Plaintiff has provided all written discovery to Defendants as well as Plaintiff’s deposition. 15. The current discovery end date is December 18, 2023. 2 CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 3 of 3 Trans ID: LCV20233377949 16. A proposed form or Order is attached. 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. _ WILLIAM J. O’KANE, JR, ESQUIRE Date: November 15, 2023 228040203 v1 3 CAM-L-002505-22 11/15/2023 11:54:59 AM Pg 1 of 1 Trans ID: LCV20233377949 ARCHER & GREINER A Professional Corporation 1025 Laurel Oak Road Voorhees, NJ 08043 (856) 795-2121 Attorneys for Plaintiff BY: WILLIAM J. O’KANE, JR., ESQUIRE (ID# 049161991) ______________________________________ _______________________________________ TRACY SNYDER SUPERIOR COURT OF NEW JERSEY LAW DIVISION Plaintiff, CAMDEN COUNTY v. DOCKET NO.: CAM-L-002505-22 GONDUL TRUCKING, INC., JHOBANY CRUZ, BURLINGTON COUNTY SPRING CERTIFICATION OF SERVICE SHOP, LLC, JOHN DOES 1-10, and ABC OF MOTION TO COMPEL ENTITIES 1-5 Defendants. CERTIFICATION OF PROOF OF SERVICE I, the undersigned, of the law firm of Archer & Greiner, P.C., attorneys for Plaintiff, Tracy Snyder in the above-entitled action, do hereby certify that On November 15, 2023, a copy of the Notice of Motion to Compel, Certification in Support of Motion, and proposed form of Order and in compliance with Rule 1:6-4, the original of the within has been E-filed with the Motion's Clerk of Camden County Superior Court, and copies have been served upon the following via the E-filing system to the following: Matthew Toto, Esquire TRAUB LIEBERMAN 322 Highway 35 3rd Floor Red Bank, NJ 07701 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. WILLIAM J. O’KANE, JR., ESQUIRE Date: November 15, 2023 228040215 v1