Preview
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 1 of 8 Trans ID: LCV20201308035
Emma K Bradley - 1294892014
DEBRA HART
ALLAIRE CORPORATE CAMPUS
5006 BELMAR BLVD SUITE A
WALL, NEW JERSEY 07727
(732) 378-4600
FAX: (732) 378-4426
Attorney for Defendants, Vanessa WilliamsMildred Williams
ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY
Plaintiff LAW DIVISION: CAMDEN COUNTY
DOCKET NO.CAM-l-1984-20
vs
VANESSA WILLIAMS, MILDRED
WILLIAMS and JOHN DOE (1-unlimited)
and ABC CORPORATION (1-unlimited) Civil Action
Defendants ANSWER AND JURY DEMAND
The defendants, Vanessa Williams (improperly pled as Venessa William) & Mildred Williams,
by way of Answer to the Complaint filed by the plaintiff, say:
PRELIMINARY AVERMENTS
1. The defendants have insufficient knowledge of the facts alleged in the first paragraph and thus
leave plaintiff to her proofs.
2. The defendants have insufficient knowledge of the facts alleged in the second paragraph and thus
leave plaintiff to her proofs.
3. The defendants have insufficient knowledge of the facts alleged in the third paragraph and thus
leave plaintiff to her proofs.
4. The defendants have insufficient knowledge of the facts alleged in the forth paragraph and thus
leave plaintiff to her proofs.
5. The defendants have insufficient knowledge of the facts alleged in the fifth paragraph and thus
leave plaintiff to her proofs.
6. The defendants have insufficient knowledge of the facts alleged in the sixth paragraph and thus
leave plaintiff to her proofs.
7. Denied.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 2 of 8 Trans ID: LCV20201308035
8. Denied.
9. Denied.
10. Denied.
WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint.
FIRST COUNT
11. The defendants repeat each of their answers to each of the allegations set forth in the previous
counts of the Complaint, and make the same a part hereof as if fully set forth herein.
12. Denied.
13. Denied
14. Denied
15. Denied.
16. Denied.
17. Denied.
18. Denied.
WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint.
SECOND COUNT
19. The defendants repeat each of their answers to each of the allegations set forth in the previous
counts of the Complaint, and make the same a part hereof as if fully set forth herein.
20. Denied.
21. Denied.
22. Denied.
23. Denied.
24. Denied.
25. Denied.
26. Denied.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 3 of 8 Trans ID: LCV20201308035
WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint.
AFFIRMATIVE DEFENSES
FIRST SEPARATE DEFENSE
The plaintiff was guilty of contributory negligence and such negligence was greater
than the negligence of these defendants. In the event such contributory negligence is adjudged
to be not greater than the negligence of these defendants, these defendants demand that the
plaintiff's damages be diminished by the percentage of plaintiff's contributory negligence under
the Comparative Negligence Act, N.J.S.2A:15-5.1, et seq.
SECOND SEPARATE DEFENSE
Any and all injuries and damages sustained were the result of a third party over whom
these defendants had no control.
THIRD SEPARATE DEFENSE
The damages of the claimant, if any, are as limited by the applicable laws of the State
of New Jersey as respects comparative negligence.
FOURTH SEPARATE DEFENSE
The damages of the claimants, if any, are as limited by the provisions of the New Jersey
Automobile Reparation Reform Act and the New Jersey Automobile Insurance Cost Reduction
Act, N.J.S.A. 39:6A-1, et. Seq.
FIFTH SEPARATE DEFENSE
Plaintiff has not been properly appointed or is otherwise without legal authority,
capacity or standing to assert the claims set forth in the Complaint.
SIXTH SEPARATE DEFENSE
These defendants were guilty of no negligence which was a proximate cause of the
injuries and damages alleged.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 4 of 8 Trans ID: LCV20201308035
SEVENTH SEPARATE DEFENSE
Plaintiff's injuries were exacerbated and aggravated by his/her/their violation of the
standards set forth in N.J.S.A. 39:3-76.2, et seq.
EIGHTH SEPARATE DEFENSE
Plaintiff's claim is barred by the Entire Controversy Doctrine.
NINTH SEPARATE DEFENSE
The claimant assumed the risk and was fully cognizant of any and all circumstances
surrounding the alleged incident.
TENTH SEPARATE DEFENSE
These defendants neither owed a duty to the plaintiff, nor did they violate any duty
which may be found to have been owing to the plaintiff.
ELEVENTH SEPARATE DEFENSE
The Complaint herein fails to state a claim upon which relief can be granted and these
defendants reserve the right to move at or before the time of trial to dismiss same.
TWELFTH SEPARATE DEFENSE
The complaint fails to state a claim upon which relief can be granted, the court lacks
jurisdiction over the subject matter of this action, and the claimant is barred from recovery as a
matter of law because the alleged claim was not made and perfected in the manner and within
the time provided and required by the law, statute, rule, regulation or contract upon which it is
predicated.
THIRTEENTH SEPARATE DEFENSE
The applicable law, rule, statute or regulation, including, but not limited to, the Statue
of Limitations, controlling or requiring the instruction of suit within a certain period of time
following its accrual, was not complied with by the claimant and, accordingly, the claimant’s
claim is barred as a matter of law.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 5 of 8 Trans ID: LCV20201308035
FOURTEENTH SEPARATE DEFENSE
The defendant reserves the right to strike the Complaint for failure of the plaintiff to
comply with R. 4:37-2 in that the Summons was not issued within 10 days after the filing of
the complaint as required by R. 4:4-1.
FIFTEENTH SEPARATE DEFENSE
Plaintiff has executed a valid and binding Release by the terms, effect and operation of
which plaintiff has released this/these defendants from liability to plaintiff for the incident and
damages complained of.
SIXTEENTH SEPARATE DEFENSE
The plaintiff’s claim asserted in this action was the subject of earlier litigation and
judicial determination and if plaintiff’s claims are collateral estopped and/or barred by reason
of the Doctrine of Res Adjudicata.
SEVENTEENTH SEPARATE DEFENSE
These defendants allege that the claim for damages asserted by plaintiff’s Complaint
has been paid and satisfied and therefore was in accord and satisfaction of all claims.
EIGHTEENTH SEPARATE DEFENSE
Plaintiff by its own actions and form of conduct has waived any and all claims that it
has against these defendants.
NINETEENTH SEPARATE DEFENSE
Plaintiff’s Complaint is defective and subject to dismissal by reason of its failure to
join indispensable parties to this action.
TWENTIETH SEPARATE DEFENSE
Plaintiff has failed to mitigate damages.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 6 of 8 Trans ID: LCV20201308035
TWENTY-FIRST SEPARATE DEFENSE
Pursuant to R.4:3-2 and/or to the Doctrine of Forum Non Conveniens, venue in this
jurisdiction is improper.
TWENTY-SECOND SEPARATE DEFENSE
Any person who fails to maintain medical expense benefits coverage pursuant to
N.J.S.A. 39:6A-4.5 is barred from recovery of economic or non-economic loss sustained as a
result of an accident while operating an uninsured motor vehicle.
TWENTY-THIRD SEPARATE DEFENSE
The court lacks jurisdiction over the subject matter of this action and these
defendants reserve the right to move for dismissal of the Complaint.
TWENTY-FOURTH SEPARATE DEFENSE
The damages of the claimant, if any, are limited by the provisions of N.J.S.A.
39:6A-8.
TWENTY-FIFTH SEPARATE DEFENSE
The defendants reserve the right to strike the complaint for failure of the plaintiff to
comply with N.J.S.A. 39:6A-8, in that the plaintiff has failed, within 60 days following the
date of these defendants' answer to the complaint, to provide the defendant/s with a
certification from the licensed treating physician or a board certified licensed physicians to
whom the plaintiff was referred by the treating physician.
TWENTY-SIXTH SEPARATE DEFENSE
There is a lack of jurisdiction over the defendants by reason of insufficiency of
process and insufficiency of service of process.
TWENTY-SEVENTH SEPARATE DEFENSE
Defendants raise and are entitled to the benefits of the Collateral Source Statute,
N.J.S.A. 2A:15-97.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 7 of 8 Trans ID: LCV20201308035
TWENTY-EIGHTH SEPARATE DEFENSE
Plaintiff is not entitled to reimbursement of medical expenses in excess of plaintiff’s
applicable PIP limit which, after application of the fee schedules approved by the
Commissioner of Banking and Insurance, total up to $250,000. Defendants reserve the right
to move for an Order requiring that all outstanding medical expenses be calculated using the
medical fee schedules as dictated by the Commissioner of Banking and Insurance and
barring plaintiff from the introduction of any evidence of any outstanding medical expenses
which, after application of the medical fee schedules approved by the Commissioner of
Banking and Insurance, total up to $250,000
TWENTY-NINTH SEPARATE DEFENSE
Plaintiff has failed to maintain medical expense benefits as mandated by N.J.S.A.
39:6A-4 and therefore his/her claim is barred by N.J.S.A. 39:6A-4.5.
DEMAND FOR ALLOCATION PURSUANT TO RULE 4:7-5(c)
If any defendant settles with the plaintiff prior to trial, these defendants will seek an
allocation by the jury of the percentage of negligence against the settling defendant. These
defendants ill seek this allocation, whether or not this defendants has formally filed a
crossclaim against the settling defendants. These defendants will rely upon the direct cross-
examination of all witnesses at trial in support of this allocation. This demand is made
pursuant to Rule 4:7-5(c) and the holding in Young v. Latta, 123 N.J. 584 (1991).
DEMAND FOR STATEMENT OF DAMAGES
PLEASE TAKE NOTICE that pursuant to R. 4:5-2, the parties filing this Answer
require that you, within five (5) days, furnish them with a Statement of the Damages claimed.
DESIGNATION OF TRIAL ATTORNEY
PLEASE TAKE NOTICE that attorney, Emma K Bradley, Esq., is hereby designated
as trial counsel in the above-captioned litigation.
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 8 of 8 Trans ID: LCV20201308035
DEMAND FOR TRIAL BY JURY
PLEASE TAKE NOTICE that this/these defendant/s demand/s a trial by Jury as to all
issues.
DEMAND FOR ANSWERS TO INTERROGATORIES
PLEASE TAKE NOTICE that pursuant to R 4:17-1, the parties filing this Answer
require that the plaintiff, provide answers to Uniform Interrogatories set forth in Form A of
Appendix II.
CERTIFICATION PURSUANT TO R. 4:5-1
I certify that there are no other pending actions or arbitration proceedings concerning
the subject matter of this action, and that no such actions or arbitration proceedings are
contemplated at this time.
Law Office of Debra Hart
Dated: July 28, 2020 By:
Emma K Bradley
Attorney for Defendants
CERTIFICATION OF MAILING
I hereby certify that an original and one copy of the within document has been filed
with the Clerk, Superior Court of New Jersey 101 South Fifth Street Camden NJ and that a
copy of same has been served upon all parties of record within the period of time allowed in
accord with R. 1:6-4 and 4:6-1.
Law Office of Debra Hart
Dated: July 28, 2020 By:
Emma K Bradley
Attorney for Defendants
CAM-L-001984-20 07/28/2020 2:28:29 PM Pg 1 of 1 Trans ID: LCV20201308035
Civil Case Information Statement
Case Details: CAMDEN | Civil Part Docket# L-001984-20
Case Caption: UNDERDUE ANGELIQUE VS WILLIAMS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
VANESSA THRESHOLD)
Case Initiation Date: 06/10/2020 Document Type: Answer
Attorney Name: EMMA KRISTINE BRADLEY Jury Demand: YES - 6 JURORS
Firm Name: LAW OFFICE OF DEBRA HART Is this a professional malpractice case? NO
Address: 303 FELLOWSHIP ROAD SUITE 300 Related cases pending: NO
MT. LAUREL NJ 08054 If yes, list docket numbers:
Phone: 8566385700 Do you anticipate adding any parties (arising out of same
Name of Party: DEFENDANT : WILLIAMS, VANESSA transaction or occurrence)? NO
Name of Defendant’s Primary Insurance Company
(if known): PALISADES SAFETY & INS ASSOC Are sexual abuse claims alleged by: ANGELIQUE UNDERDUE?
NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:
Will an interpreter be needed? NO
If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
07/28/2020 /s/ EMMA KRISTINE BRADLEY
Dated Signed
Preview
CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 1 of 8 Trans ID: LCV20201308035 Emma K Bradley - 1294892014 DEBRA HART ALLAIRE CORPORATE CAMPUS 5006 BELMAR BLVD SUITE A WALL, NEW JERSEY 07727 (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendants, Vanessa WilliamsMildred Williams ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY Plaintiff LAW DIVISION: CAMDEN COUNTY DOCKET NO.CAM-l-1984-20 vs VANESSA WILLIAMS, MILDRED WILLIAMS and JOHN DOE (1-unlimited) and ABC CORPORATION (1-unlimited) Civil Action Defendants ANSWER AND JURY DEMAND The defendants, Vanessa Williams (improperly pled as Venessa William) & Mildred Williams, by way of Answer to the Complaint filed by the plaintiff, say: PRELIMINARY AVERMENTS 1. The defendants have insufficient knowledge of the facts alleged in the first paragraph and thus leave plaintiff to her proofs. 2. The defendants have insufficient knowledge of the facts alleged in the second paragraph and thus leave plaintiff to her proofs. 3. The defendants have insufficient knowledge of the facts alleged in the third paragraph and thus leave plaintiff to her proofs. 4. The defendants have insufficient knowledge of the facts alleged in the forth paragraph and thus leave plaintiff to her proofs. 5. The defendants have insufficient knowledge of the facts alleged in the fifth paragraph and thus leave plaintiff to her proofs. 6. The defendants have insufficient knowledge of the facts alleged in the sixth paragraph and thus leave plaintiff to her proofs. 7. Denied. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 2 of 8 Trans ID: LCV20201308035 8. Denied. 9. Denied. 10. Denied. WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint. FIRST COUNT 11. The defendants repeat each of their answers to each of the allegations set forth in the previous counts of the Complaint, and make the same a part hereof as if fully set forth herein. 12. Denied. 13. Denied 14. Denied 15. Denied. 16. Denied. 17. Denied. 18. Denied. WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint. SECOND COUNT 19. The defendants repeat each of their answers to each of the allegations set forth in the previous counts of the Complaint, and make the same a part hereof as if fully set forth herein. 20. Denied. 21. Denied. 22. Denied. 23. Denied. 24. Denied. 25. Denied. 26. Denied. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 3 of 8 Trans ID: LCV20201308035 WHEREFORE, these defendants demand judgment dismissing plaintiff's Complaint. AFFIRMATIVE DEFENSES FIRST SEPARATE DEFENSE The plaintiff was guilty of contributory negligence and such negligence was greater than the negligence of these defendants. In the event such contributory negligence is adjudged to be not greater than the negligence of these defendants, these defendants demand that the plaintiff's damages be diminished by the percentage of plaintiff's contributory negligence under the Comparative Negligence Act, N.J.S.2A:15-5.1, et seq. SECOND SEPARATE DEFENSE Any and all injuries and damages sustained were the result of a third party over whom these defendants had no control. THIRD SEPARATE DEFENSE The damages of the claimant, if any, are as limited by the applicable laws of the State of New Jersey as respects comparative negligence. FOURTH SEPARATE DEFENSE The damages of the claimants, if any, are as limited by the provisions of the New Jersey Automobile Reparation Reform Act and the New Jersey Automobile Insurance Cost Reduction Act, N.J.S.A. 39:6A-1, et. Seq. FIFTH SEPARATE DEFENSE Plaintiff has not been properly appointed or is otherwise without legal authority, capacity or standing to assert the claims set forth in the Complaint. SIXTH SEPARATE DEFENSE These defendants were guilty of no negligence which was a proximate cause of the injuries and damages alleged. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 4 of 8 Trans ID: LCV20201308035 SEVENTH SEPARATE DEFENSE Plaintiff's injuries were exacerbated and aggravated by his/her/their violation of the standards set forth in N.J.S.A. 39:3-76.2, et seq. EIGHTH SEPARATE DEFENSE Plaintiff's claim is barred by the Entire Controversy Doctrine. NINTH SEPARATE DEFENSE The claimant assumed the risk and was fully cognizant of any and all circumstances surrounding the alleged incident. TENTH SEPARATE DEFENSE These defendants neither owed a duty to the plaintiff, nor did they violate any duty which may be found to have been owing to the plaintiff. ELEVENTH SEPARATE DEFENSE The Complaint herein fails to state a claim upon which relief can be granted and these defendants reserve the right to move at or before the time of trial to dismiss same. TWELFTH SEPARATE DEFENSE The complaint fails to state a claim upon which relief can be granted, the court lacks jurisdiction over the subject matter of this action, and the claimant is barred from recovery as a matter of law because the alleged claim was not made and perfected in the manner and within the time provided and required by the law, statute, rule, regulation or contract upon which it is predicated. THIRTEENTH SEPARATE DEFENSE The applicable law, rule, statute or regulation, including, but not limited to, the Statue of Limitations, controlling or requiring the instruction of suit within a certain period of time following its accrual, was not complied with by the claimant and, accordingly, the claimant’s claim is barred as a matter of law. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 5 of 8 Trans ID: LCV20201308035 FOURTEENTH SEPARATE DEFENSE The defendant reserves the right to strike the Complaint for failure of the plaintiff to comply with R. 4:37-2 in that the Summons was not issued within 10 days after the filing of the complaint as required by R. 4:4-1. FIFTEENTH SEPARATE DEFENSE Plaintiff has executed a valid and binding Release by the terms, effect and operation of which plaintiff has released this/these defendants from liability to plaintiff for the incident and damages complained of. SIXTEENTH SEPARATE DEFENSE The plaintiff’s claim asserted in this action was the subject of earlier litigation and judicial determination and if plaintiff’s claims are collateral estopped and/or barred by reason of the Doctrine of Res Adjudicata. SEVENTEENTH SEPARATE DEFENSE These defendants allege that the claim for damages asserted by plaintiff’s Complaint has been paid and satisfied and therefore was in accord and satisfaction of all claims. EIGHTEENTH SEPARATE DEFENSE Plaintiff by its own actions and form of conduct has waived any and all claims that it has against these defendants. NINETEENTH SEPARATE DEFENSE Plaintiff’s Complaint is defective and subject to dismissal by reason of its failure to join indispensable parties to this action. TWENTIETH SEPARATE DEFENSE Plaintiff has failed to mitigate damages. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 6 of 8 Trans ID: LCV20201308035 TWENTY-FIRST SEPARATE DEFENSE Pursuant to R.4:3-2 and/or to the Doctrine of Forum Non Conveniens, venue in this jurisdiction is improper. TWENTY-SECOND SEPARATE DEFENSE Any person who fails to maintain medical expense benefits coverage pursuant to N.J.S.A. 39:6A-4.5 is barred from recovery of economic or non-economic loss sustained as a result of an accident while operating an uninsured motor vehicle. TWENTY-THIRD SEPARATE DEFENSE The court lacks jurisdiction over the subject matter of this action and these defendants reserve the right to move for dismissal of the Complaint. TWENTY-FOURTH SEPARATE DEFENSE The damages of the claimant, if any, are limited by the provisions of N.J.S.A. 39:6A-8. TWENTY-FIFTH SEPARATE DEFENSE The defendants reserve the right to strike the complaint for failure of the plaintiff to comply with N.J.S.A. 39:6A-8, in that the plaintiff has failed, within 60 days following the date of these defendants' answer to the complaint, to provide the defendant/s with a certification from the licensed treating physician or a board certified licensed physicians to whom the plaintiff was referred by the treating physician. TWENTY-SIXTH SEPARATE DEFENSE There is a lack of jurisdiction over the defendants by reason of insufficiency of process and insufficiency of service of process. TWENTY-SEVENTH SEPARATE DEFENSE Defendants raise and are entitled to the benefits of the Collateral Source Statute, N.J.S.A. 2A:15-97. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 7 of 8 Trans ID: LCV20201308035 TWENTY-EIGHTH SEPARATE DEFENSE Plaintiff is not entitled to reimbursement of medical expenses in excess of plaintiff’s applicable PIP limit which, after application of the fee schedules approved by the Commissioner of Banking and Insurance, total up to $250,000. Defendants reserve the right to move for an Order requiring that all outstanding medical expenses be calculated using the medical fee schedules as dictated by the Commissioner of Banking and Insurance and barring plaintiff from the introduction of any evidence of any outstanding medical expenses which, after application of the medical fee schedules approved by the Commissioner of Banking and Insurance, total up to $250,000 TWENTY-NINTH SEPARATE DEFENSE Plaintiff has failed to maintain medical expense benefits as mandated by N.J.S.A. 39:6A-4 and therefore his/her claim is barred by N.J.S.A. 39:6A-4.5. DEMAND FOR ALLOCATION PURSUANT TO RULE 4:7-5(c) If any defendant settles with the plaintiff prior to trial, these defendants will seek an allocation by the jury of the percentage of negligence against the settling defendant. These defendants ill seek this allocation, whether or not this defendants has formally filed a crossclaim against the settling defendants. These defendants will rely upon the direct cross- examination of all witnesses at trial in support of this allocation. This demand is made pursuant to Rule 4:7-5(c) and the holding in Young v. Latta, 123 N.J. 584 (1991). DEMAND FOR STATEMENT OF DAMAGES PLEASE TAKE NOTICE that pursuant to R. 4:5-2, the parties filing this Answer require that you, within five (5) days, furnish them with a Statement of the Damages claimed. DESIGNATION OF TRIAL ATTORNEY PLEASE TAKE NOTICE that attorney, Emma K Bradley, Esq., is hereby designated as trial counsel in the above-captioned litigation. CAM-L-001984-20 07/28/2020 2:28:28 PM Pg 8 of 8 Trans ID: LCV20201308035 DEMAND FOR TRIAL BY JURY PLEASE TAKE NOTICE that this/these defendant/s demand/s a trial by Jury as to all issues. DEMAND FOR ANSWERS TO INTERROGATORIES PLEASE TAKE NOTICE that pursuant to R 4:17-1, the parties filing this Answer require that the plaintiff, provide answers to Uniform Interrogatories set forth in Form A of Appendix II. CERTIFICATION PURSUANT TO R. 4:5-1 I certify that there are no other pending actions or arbitration proceedings concerning the subject matter of this action, and that no such actions or arbitration proceedings are contemplated at this time. Law Office of Debra Hart Dated: July 28, 2020 By: Emma K Bradley Attorney for Defendants CERTIFICATION OF MAILING I hereby certify that an original and one copy of the within document has been filed with the Clerk, Superior Court of New Jersey 101 South Fifth Street Camden NJ and that a copy of same has been served upon all parties of record within the period of time allowed in accord with R. 1:6-4 and 4:6-1. Law Office of Debra Hart Dated: July 28, 2020 By: Emma K Bradley Attorney for Defendants CAM-L-001984-20 07/28/2020 2:28:29 PM Pg 1 of 1 Trans ID: LCV20201308035 Civil Case Information Statement Case Details: CAMDEN | Civil Part Docket# L-001984-20 Case Caption: UNDERDUE ANGELIQUE VS WILLIAMS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL VANESSA THRESHOLD) Case Initiation Date: 06/10/2020 Document Type: Answer Attorney Name: EMMA KRISTINE BRADLEY Jury Demand: YES - 6 JURORS Firm Name: LAW OFFICE OF DEBRA HART Is this a professional malpractice case? NO Address: 303 FELLOWSHIP ROAD SUITE 300 Related cases pending: NO MT. LAUREL NJ 08054 If yes, list docket numbers: Phone: 8566385700 Do you anticipate adding any parties (arising out of same Name of Party: DEFENDANT : WILLIAMS, VANESSA transaction or occurrence)? NO Name of Defendant’s Primary Insurance Company (if known): PALISADES SAFETY & INS ASSOC Are sexual abuse claims alleged by: ANGELIQUE UNDERDUE? NO THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION Do parties have a current, past, or recurrent relationship? NO If yes, is that relationship: Does the statute governing this case provide for payment of fees by the losing party? NO Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition: Do you or your client need any disability accommodations? NO If yes, please identify the requested accommodation: Will an interpreter be needed? NO If yes, for what language: Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO I certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b) 07/28/2020 /s/ EMMA KRISTINE BRADLEY Dated Signed