Preview
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 1 of 5 Trans ID: LCV20211602159
Law Office
of
DEBRA HART
DEBRA HART ++ CATHERINE MASTERSON
581 MAIN STREET
EMMA K. BRADLEY ++
SUITE 801
BARBARA S. SHERIDAN STEVEN I. GREENBERG
WOODBRIDGE, NEW JERSEY 07095
MARY E. MCLAUGHLIN* (732) 378-4600 ANTHONY F. BELOTTA
KEVIN J. SAVAGE +++ Fax: (732) 378-4426 VANESA L. RIDORE +
ALLISON T. KURTZ EVAN C.CAMHI +
Employees of Palisades/High Point Insurance Group
+ NJ & NY BARS
++ NJ & PA BARS
+++ NJ NY DC & WA BARS
* CERTIFIED BY THE SUPREME COURT OF NEW
JERSEY AS A CIVIL TRIAL ATTORNEY
Attorney Direct: 856-638-5710 cell 732-275-5595 Email: EKBAssist@dahart-law.com
Secretary Direct: 732-378-4437
July 2, 2021
Camden County Superior Court
101 South Fifth Street
Camden, NJ 08103
Re: Underdue vs Williams
Our FileNo:686401682764
Docket No:CAM-L-1984-20
Dear Sir/Madam:
Enclosed please find documents listed below:
(X) Notice of Motion
(X) Certification
(X) Order
(X) Please charge the filing fee to our collateral account 144293.
(X) Please file
Very truly yours,
By:_________________________
Emma K Bradley
EKB/kf
cc: Jerry Gallagher/Parsippany Claims Office/686401682764
Marc I Simon Esq
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 2 of 5 Trans ID: LCV20211602159
Emma K Bradley - 129492014
DEBRA HART
581 MAIN STREET
SUITE 801
WOODBRIDGE NJ 07095
(732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Vanessa Williams and Mildred Williams
ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CAMDEN COUNTY
Plaintiff DOCKET NO.CAM-L-1984-20
Civil Action
vs NOTICE OF MOTION TO EXTEND
DISCOVERY PERIOD Pursuant to
VENESSA WILLIAMS, MILDRED Rule 4:24-1(c)
WILLIAMS and JOHN DOE (1-unlimited)
and ABC CORPORATION (1-unlimited)
Defendants
TO: Marc I Simon Esq
Simon & Simon
401 Market St
Camden NJ 08101
SIRS:
PLEASE TAKE NOTICE that on 7/23/2021, at 9:00 A.M. or as soon thereafter as Counsel
may be heard, the undersigned, attorney for defendant/s, Vanessa WilliamsMildred Williams shall
apply to the Court for an Order to Extend the Discovery Period.
IN SUPPORT HEREOF, we shall rely upon the Certification of Emma K Bradley, Esq.,
attached hereto and made a part of the moving papers submitted.
IT IS respectfully requested that this matter be submitted to the Court for ruling on the papers
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 3 of 5 Trans ID: LCV20211602159
pursuant to the applicable provisions of Rule 1:6-2.
Law Office of Debra Hart
Dated: July 2, 2021 By: ___________
Emma K Bradley
PROCEDURAL HISTORY:
Complaint filed on:
Summons issued:
Answer filed on: 7/29/2020
Discovery End Date: 7/23/2021
Settlement Conf:
Arbitration Date:
Trial Date:
Pursuant to Rule 1:6-2(d), the undersigned:
( X ) Waives oral argument and consents to disposition on the papers
( ) Requests oral argument if opposition filed
( ) Requests oral argument
I certify that the moving party has either attempted to personally confer orally with the
opposing party or has advised the opposing party by letter that after the default occurred, that
continued non-compliance with discovery obligations will result in an appropriate Motion being
made without further attempt to resolve this matter.
PROOF 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 Camden County Superior Court 101 South Fifth Street Camden, NJ
08103 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 2, 2021 By: ___________
Emma K Bradley
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 4 of 5 Trans ID: LCV20211602159
CERTIFICATION
I, Emma K Bradley of full age, hereby certify the following:
1. I am An Attorney-at-Law of the State of New Jersey, and am associated with the Law Office
of Debra Hart . I have been assigned personal handling of and am familiar with the above-captioned
matter.
2. The Discovery End Date in this case is 7/23/2021.
3. The defendants request an extension of discovery until October 25, 2021.
4. There is good cause justifying the within request as required by the Rules because defendant is
waiting for plaintiff to provide the response to the Notice to Produce which was compelled and due by
June 24, 2021. To date no response has been received. Records from CamCam, originally requested via
authorization on 3/11/21. We received notification that they require a specialized authorization which
was sent to plaintiff for signing. Same was received from plaintiff and sent back to the facility on
6/11/21.
5. Records from Upright MRI and Cooper Radiology have been requested on July 1, 2021.
6. The IME has been scheduled for 8/3/21.
7. Additional time will be needed to get the records from the various providers and plaintiffs
response to the Notice to Produce to the IME doctor for his review and an addendum report.
8. It is anticipated that all of the required discovery will be completed by October 25, 2021.
9. I hereby certify that there have been no prior Orders Extending Discovery entered as a result of
a Notice of Motion in this matter.
10. I know of no settlement conference date, arbitration date or trial date.
11. I further certify that all statements contained herein are true to the best of my knowledge. I
am aware that if any such statements are willfully false, I am subject to punishment.
Dated: July 2, 2021 _________________________________
Emma K Bradley
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 5 of 5 Trans ID: LCV20211602159
Emma K Bradley - 129492014
DEBRA HART
581 MAIN STREET
SUITE 801
WOODBRIDGE NJ 07095
(732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Vanessa Williams and Mildred Williams
ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CAMDEN COUNTY
Plaintiff DOCKET NO.CAM-L-1984-20
Civil Action
vs
ORDER EXTENDING DISCOVERY
VENESSA WILLIAMS, MILDRED PERIOD Pursuant to Rule 4:24-1(c)
WILLIAMS and JOHN DOE (1-unlimited)
and ABC CORPORATION (1-unlimited)
Defendants
THIS MATTER having been placed before the Court by the Law Office of Debra Hart
attorney for the defendant/s, Vanessa Williams and Mildred Williams ; and the Court having
considered the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
ORDERED that the time for the completion of discovery is hereby extended to October 25,
2021;
IT IS FURTHER ORDERED that, within the extended discovery period, the parties are to
complete the following discovery matters as specifically indicated below:
Item Scheduled For
1. Plaintiff to respond to the court ordered July 30, 2021
NTP
2. Plaintiff to attend IME September 1, 2021
3. Films obtained from providers August 15, 2021
4. Obtain outstanding records from providers October 1, 2021
5.Examination/Addendum Report served on October 25, 2021
adversary
IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon
all parties upon its upload to eCourts.
. ________________________________
, J.S.C.
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 1 of 1 Trans ID: LCV20211602159
Emma K Bradley - 129492014
DEBRA HART
581 MAIN STREET
SUITE 801
WOODBRIDGE NJ 07095
(732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant/s, Vanessa Williams and Mildred Williams
ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CAMDEN COUNTY
Plaintiff DOCKET NO.CAM-L-1984-20
Civil Action
vs
ORDER EXTENDING DISCOVERY
VENESSA WILLIAMS, MILDRED PERIOD Pursuant to Rule 4:24-1(c)
WILLIAMS and JOHN DOE (1-unlimited)
and ABC CORPORATION (1-unlimited)
Defendants
THIS MATTER having been placed before the Court by the Law Office of Debra Hart
attorney for the defendant/s, Vanessa Williams and Mildred Williams ; and the Court having
considered the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
ORDERED that the time for the completion of discovery is hereby extended to October 25,
2021;
IT IS FURTHER ORDERED that, within the extended discovery period, the parties are to
complete the following discovery matters as specifically indicated below:
Item Scheduled For
1. Plaintiff to respond to the court ordered July 30, 2021
NTP
2. Plaintiff to attend IME September 1, 2021
3. Films obtained from providers August 15, 2021
4. Obtain outstanding records from providers October 1, 2021
5.Examination/Addendum Report served on October 25, 2021
adversary
IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon
all parties upon its upload to eCourts.
. ________________________________
, J.S.C.
Preview
CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 1 of 5 Trans ID: LCV20211602159 Law Office of DEBRA HART DEBRA HART ++ CATHERINE MASTERSON 581 MAIN STREET EMMA K. BRADLEY ++ SUITE 801 BARBARA S. SHERIDAN STEVEN I. GREENBERG WOODBRIDGE, NEW JERSEY 07095 MARY E. MCLAUGHLIN* (732) 378-4600 ANTHONY F. BELOTTA KEVIN J. SAVAGE +++ Fax: (732) 378-4426 VANESA L. RIDORE + ALLISON T. KURTZ EVAN C.CAMHI + Employees of Palisades/High Point Insurance Group + NJ & NY BARS ++ NJ & PA BARS +++ NJ NY DC & WA BARS * CERTIFIED BY THE SUPREME COURT OF NEW JERSEY AS A CIVIL TRIAL ATTORNEY Attorney Direct: 856-638-5710 cell 732-275-5595 Email: EKBAssist@dahart-law.com Secretary Direct: 732-378-4437 July 2, 2021 Camden County Superior Court 101 South Fifth Street Camden, NJ 08103 Re: Underdue vs Williams Our FileNo:686401682764 Docket No:CAM-L-1984-20 Dear Sir/Madam: Enclosed please find documents listed below: (X) Notice of Motion (X) Certification (X) Order (X) Please charge the filing fee to our collateral account 144293. (X) Please file Very truly yours, By:_________________________ Emma K Bradley EKB/kf cc: Jerry Gallagher/Parsippany Claims Office/686401682764 Marc I Simon Esq CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 2 of 5 Trans ID: LCV20211602159 Emma K Bradley - 129492014 DEBRA HART 581 MAIN STREET SUITE 801 WOODBRIDGE NJ 07095 (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Vanessa Williams and Mildred Williams ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY LAW DIVISION: CAMDEN COUNTY Plaintiff DOCKET NO.CAM-L-1984-20 Civil Action vs NOTICE OF MOTION TO EXTEND DISCOVERY PERIOD Pursuant to VENESSA WILLIAMS, MILDRED Rule 4:24-1(c) WILLIAMS and JOHN DOE (1-unlimited) and ABC CORPORATION (1-unlimited) Defendants TO: Marc I Simon Esq Simon & Simon 401 Market St Camden NJ 08101 SIRS: PLEASE TAKE NOTICE that on 7/23/2021, at 9:00 A.M. or as soon thereafter as Counsel may be heard, the undersigned, attorney for defendant/s, Vanessa WilliamsMildred Williams shall apply to the Court for an Order to Extend the Discovery Period. IN SUPPORT HEREOF, we shall rely upon the Certification of Emma K Bradley, Esq., attached hereto and made a part of the moving papers submitted. IT IS respectfully requested that this matter be submitted to the Court for ruling on the papers CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 3 of 5 Trans ID: LCV20211602159 pursuant to the applicable provisions of Rule 1:6-2. Law Office of Debra Hart Dated: July 2, 2021 By: ___________ Emma K Bradley PROCEDURAL HISTORY: Complaint filed on: Summons issued: Answer filed on: 7/29/2020 Discovery End Date: 7/23/2021 Settlement Conf: Arbitration Date: Trial Date: Pursuant to Rule 1:6-2(d), the undersigned: ( X ) Waives oral argument and consents to disposition on the papers ( ) Requests oral argument if opposition filed ( ) Requests oral argument I certify that the moving party has either attempted to personally confer orally with the opposing party or has advised the opposing party by letter that after the default occurred, that continued non-compliance with discovery obligations will result in an appropriate Motion being made without further attempt to resolve this matter. PROOF 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 Camden County Superior Court 101 South Fifth Street Camden, NJ 08103 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 2, 2021 By: ___________ Emma K Bradley CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 4 of 5 Trans ID: LCV20211602159 CERTIFICATION I, Emma K Bradley of full age, hereby certify the following: 1. I am An Attorney-at-Law of the State of New Jersey, and am associated with the Law Office of Debra Hart . I have been assigned personal handling of and am familiar with the above-captioned matter. 2. The Discovery End Date in this case is 7/23/2021. 3. The defendants request an extension of discovery until October 25, 2021. 4. There is good cause justifying the within request as required by the Rules because defendant is waiting for plaintiff to provide the response to the Notice to Produce which was compelled and due by June 24, 2021. To date no response has been received. Records from CamCam, originally requested via authorization on 3/11/21. We received notification that they require a specialized authorization which was sent to plaintiff for signing. Same was received from plaintiff and sent back to the facility on 6/11/21. 5. Records from Upright MRI and Cooper Radiology have been requested on July 1, 2021. 6. The IME has been scheduled for 8/3/21. 7. Additional time will be needed to get the records from the various providers and plaintiffs response to the Notice to Produce to the IME doctor for his review and an addendum report. 8. It is anticipated that all of the required discovery will be completed by October 25, 2021. 9. I hereby certify that there have been no prior Orders Extending Discovery entered as a result of a Notice of Motion in this matter. 10. I know of no settlement conference date, arbitration date or trial date. 11. I further certify that all statements contained herein are true to the best of my knowledge. I am aware that if any such statements are willfully false, I am subject to punishment. Dated: July 2, 2021 _________________________________ Emma K Bradley CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 5 of 5 Trans ID: LCV20211602159 Emma K Bradley - 129492014 DEBRA HART 581 MAIN STREET SUITE 801 WOODBRIDGE NJ 07095 (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Vanessa Williams and Mildred Williams ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY LAW DIVISION: CAMDEN COUNTY Plaintiff DOCKET NO.CAM-L-1984-20 Civil Action vs ORDER EXTENDING DISCOVERY VENESSA WILLIAMS, MILDRED PERIOD Pursuant to Rule 4:24-1(c) WILLIAMS and JOHN DOE (1-unlimited) and ABC CORPORATION (1-unlimited) Defendants THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the defendant/s, Vanessa Williams and Mildred Williams ; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; ORDERED that the time for the completion of discovery is hereby extended to October 25, 2021; IT IS FURTHER ORDERED that, within the extended discovery period, the parties are to complete the following discovery matters as specifically indicated below: Item Scheduled For 1. Plaintiff to respond to the court ordered July 30, 2021 NTP 2. Plaintiff to attend IME September 1, 2021 3. Films obtained from providers August 15, 2021 4. Obtain outstanding records from providers October 1, 2021 5.Examination/Addendum Report served on October 25, 2021 adversary IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. . ________________________________ , J.S.C. CAM-L-001984-20 07/07/2021 2:48:51 PM Pg 1 of 1 Trans ID: LCV20211602159 Emma K Bradley - 129492014 DEBRA HART 581 MAIN STREET SUITE 801 WOODBRIDGE NJ 07095 (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant/s, Vanessa Williams and Mildred Williams ANGELIQUE UNDERDUE SUPERIOR COURT OF NEW JERSEY LAW DIVISION: CAMDEN COUNTY Plaintiff DOCKET NO.CAM-L-1984-20 Civil Action vs ORDER EXTENDING DISCOVERY VENESSA WILLIAMS, MILDRED PERIOD Pursuant to Rule 4:24-1(c) WILLIAMS and JOHN DOE (1-unlimited) and ABC CORPORATION (1-unlimited) Defendants THIS MATTER having been placed before the Court by the Law Office of Debra Hart attorney for the defendant/s, Vanessa Williams and Mildred Williams ; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; ORDERED that the time for the completion of discovery is hereby extended to October 25, 2021; IT IS FURTHER ORDERED that, within the extended discovery period, the parties are to complete the following discovery matters as specifically indicated below: Item Scheduled For 1. Plaintiff to respond to the court ordered July 30, 2021 NTP 2. Plaintiff to attend IME September 1, 2021 3. Films obtained from providers August 15, 2021 4. Obtain outstanding records from providers October 1, 2021 5.Examination/Addendum Report served on October 25, 2021 adversary IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. . ________________________________ , J.S.C.