Preview
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 1 of 7 Trans ID: LCV20212329814
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
October 6, 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: Barry Deutch/Parsippany Claims Office/686401682764
Marc I Simon
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 2 of 7 Trans ID: LCV20212329814
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
vs Civil Action
VENESSA WILLIAMS, MILDRED NOTICE OF MOTION TO EXTEND
WILLIAMS and JOHN DOE (1-unlimited) DISCOVERY AND COMPEL
and ABC CORPORATION (1-unlimited)
Defendants
TO: Marc I Simon Esq
SIMON & SIMON PC
1818 Market StreetSuite 200
PhiladelphiaPA 19103
SIRS:
PLEASE TAKE NOTICE that on 10/22/2021, at 9:00 A.M. or as soon thereafter as
Counsel may be heard, the undersigned, attorney for defendant/s,Vanessa Williams and Mildred
Williams shall apply to the Court for an Order compelling plaintiff/s, Angelique Underdue, to Compel
authorization from Pennsauken Diagnostic Center, the document in response to the Notice to
Produce, extend discovery and adjourn the arbitration.
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
pursuant to the applicable provisions of Rule 1:6-2.
Law Office of Debra Hart
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 3 of 7 Trans ID: LCV20212329814
Dated: October 6, 2021 By: ___________
Emma K Bradley
PROCEDURAL HISTORY:
Complaint filed on:
Summons issued:
Answer filed on: 7/29/2020
Discovery End Date: 10/25/2021
Settlement Conf:
Arbitration Date: 11/10/2021
Trial Date:
Pursuant to Rule 1:6-2(d), the undersigned:
( ) Waives oral argument and consents to disposition on the papers
(X) 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: October 6, 2021 By: ___________
Emma K Bradley
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 4 of 7 Trans ID: LCV20212329814
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 10/25/2021.
3. The defendants request an extension of discovery until January 15, 2022.
4. There is good cause justifying the within request as required by the Rules because defendant is
waiting for plaintiff to provide the signed authorization for the films from Pennsauken Diagnostic
Center, as notice of those films from June 2020 as just received in August 2021, and an authorization
was sent out immediately. Our Office served its first follow up by letter dated October 5, 2021 since
plaintiff has not responded to our request in a timely fashion.
5. A clear copy of the declaration page – initially requested with filing of defendant’s answer,
compelled previously by court order dated 5/14/2021; motion to dismiss filed based upon same but
was denied – however still no clear copy of declaration page received to date. Defendant
respectfully requests that the Court compel the plaintiff to produce the declaration page within ten
days of the entry of the Order.
6. Defendant respectfully requests that the Court enter an Order compelling the plaintiff to produce
the authorization directed to Pennsauken Diagnostic Center within twenty days of the entry of the
Order and allow defendant an extension in discovery to be allowed to obtain the film studies and
provide them to its defense expert for review and an addendum report to be issued and served on
plaintiff’s counsel.
7. Defendant has served authorizations to Upright MRI of Cherry Hill and issue payment for the
film studies and when same were not produced in a timely manner learned that the facility had not
printed the studies when payment had been received, nor did they have postage funds available to
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 5 of 7 Trans ID: LCV20212329814
ship the studies to our office. We are in the process of having the films picked up from the facility
once we have been notified that the films are ready. Defendant served an authorization to Cooper
University Radiology and through a third party vendor the films were requested but our office has
not received, another copy has been requested and is in the process of being sent to our office. Once
received, defendant will need additional time to have them reviewed by our medical expert and an
addendum report issued and served on counsel for plaintiff.
8. It is anticipated that all of the required discovery will be completed by January 15, 2022.
9. Pursuant to R.4:24-1(c), there have been prior Orders to extend, copies of which uploaded by the
Court under Trans ID LCV20211728523 on July 23, 2021.
10. There is scheduled an Arbitration hearing on November 10, 2021 which defendant respectfully
requests be adjourned to allow for the discovery extension.
11. I hereby certify that the moving party is not in default of discovery.
12. I 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: October 6, 2021 ___________
Emma K Bradley
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 6 of 7 Trans ID: LCV20212329814
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
vs Civil Action
VENESSA WILLIAMS, MILDRED ORDER TO EXTEND DISCOVERY AND
WILLIAMS and JOHN DOE (1-unlimited) COMPEL
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 WilliamsMildred Williams; and the Court having considered
the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce
within ten days of the entry of the Order the clear copy of the declaration page of insurance which
was previously court ordered on 5/14/2021; and
IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce
within 20 days of the entry of this Order the signed authorization directed to Pennsauken Diagnostic
Center and a clear copy of the declaration page of insurance which was previously compelled by
order dated 5/14/2021
IT IS FURTHER ORDERED that if plaintiff/s, shall fail to comply such further relief as
this court may deem appropriate; and
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 7 of 7 Trans ID: LCV20212329814
IT IS FURTHER ORDERED that if plaintiff/defendant shall fail to comply with the terms
of this Order, the moving party may have the right to submit an Ex Parte Affidavit requesting the
dismissal of plaintiff’s/s’ Complaint/suppression of co-defendant’s/s’ Answer and Defenses; and
ORDERED that the time for the completion of discovery is hereby extended to January 15,
2022;
IT IS FURTHER ORDERED that the Arbitration date of 11/10/2021 is hereby adjourned to
allow for the discovery extension;
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. All MRI Films to IME doctor for November 15, 2021
Addendum Report
2. Addendum Report served on adversary January 15, 2022
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 10/06/2021 4:40:23 PM Pg 1 of 2 Trans ID: LCV20212329814
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
vs Civil Action
VENESSA WILLIAMS, MILDRED ORDER TO EXTEND DISCOVERY AND
WILLIAMS and JOHN DOE (1-unlimited) COMPEL
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 WilliamsMildred Williams; and the Court having considered
the moving papers of the parties; and for good cause shown;
IT IS, on this day of , 20 ;
IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce
within ten days of the entry of the Order the clear copy of the declaration page of insurance which
was previously court ordered on 5/14/2021; and
IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce
within 20 days of the entry of this Order the signed authorization directed to Pennsauken Diagnostic
Center and a clear copy of the declaration page of insurance which was previously compelled by
order dated 5/14/2021
IT IS FURTHER ORDERED that if plaintiff/s, shall fail to comply such further relief as
this court may deem appropriate; and
CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 2 of 2 Trans ID: LCV20212329814
IT IS FURTHER ORDERED that if plaintiff/defendant shall fail to comply with the terms
of this Order, the moving party may have the right to submit an Ex Parte Affidavit requesting the
dismissal of plaintiff’s/s’ Complaint/suppression of co-defendant’s/s’ Answer and Defenses; and
ORDERED that the time for the completion of discovery is hereby extended to January 15,
2022;
IT IS FURTHER ORDERED that the Arbitration date of 11/10/2021 is hereby adjourned to
allow for the discovery extension;
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. All MRI Films to IME doctor for November 15, 2021
Addendum Report
2. Addendum Report served on adversary January 15, 2022
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 10/06/2021 4:40:23 PM Pg 1 of 7 Trans ID: LCV20212329814 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 October 6, 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: Barry Deutch/Parsippany Claims Office/686401682764 Marc I Simon CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 2 of 7 Trans ID: LCV20212329814 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 vs Civil Action VENESSA WILLIAMS, MILDRED NOTICE OF MOTION TO EXTEND WILLIAMS and JOHN DOE (1-unlimited) DISCOVERY AND COMPEL and ABC CORPORATION (1-unlimited) Defendants TO: Marc I Simon Esq SIMON & SIMON PC 1818 Market StreetSuite 200 PhiladelphiaPA 19103 SIRS: PLEASE TAKE NOTICE that on 10/22/2021, at 9:00 A.M. or as soon thereafter as Counsel may be heard, the undersigned, attorney for defendant/s,Vanessa Williams and Mildred Williams shall apply to the Court for an Order compelling plaintiff/s, Angelique Underdue, to Compel authorization from Pennsauken Diagnostic Center, the document in response to the Notice to Produce, extend discovery and adjourn the arbitration. 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 pursuant to the applicable provisions of Rule 1:6-2. Law Office of Debra Hart CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 3 of 7 Trans ID: LCV20212329814 Dated: October 6, 2021 By: ___________ Emma K Bradley PROCEDURAL HISTORY: Complaint filed on: Summons issued: Answer filed on: 7/29/2020 Discovery End Date: 10/25/2021 Settlement Conf: Arbitration Date: 11/10/2021 Trial Date: Pursuant to Rule 1:6-2(d), the undersigned: ( ) Waives oral argument and consents to disposition on the papers (X) 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: October 6, 2021 By: ___________ Emma K Bradley CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 4 of 7 Trans ID: LCV20212329814 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 10/25/2021. 3. The defendants request an extension of discovery until January 15, 2022. 4. There is good cause justifying the within request as required by the Rules because defendant is waiting for plaintiff to provide the signed authorization for the films from Pennsauken Diagnostic Center, as notice of those films from June 2020 as just received in August 2021, and an authorization was sent out immediately. Our Office served its first follow up by letter dated October 5, 2021 since plaintiff has not responded to our request in a timely fashion. 5. A clear copy of the declaration page – initially requested with filing of defendant’s answer, compelled previously by court order dated 5/14/2021; motion to dismiss filed based upon same but was denied – however still no clear copy of declaration page received to date. Defendant respectfully requests that the Court compel the plaintiff to produce the declaration page within ten days of the entry of the Order. 6. Defendant respectfully requests that the Court enter an Order compelling the plaintiff to produce the authorization directed to Pennsauken Diagnostic Center within twenty days of the entry of the Order and allow defendant an extension in discovery to be allowed to obtain the film studies and provide them to its defense expert for review and an addendum report to be issued and served on plaintiff’s counsel. 7. Defendant has served authorizations to Upright MRI of Cherry Hill and issue payment for the film studies and when same were not produced in a timely manner learned that the facility had not printed the studies when payment had been received, nor did they have postage funds available to CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 5 of 7 Trans ID: LCV20212329814 ship the studies to our office. We are in the process of having the films picked up from the facility once we have been notified that the films are ready. Defendant served an authorization to Cooper University Radiology and through a third party vendor the films were requested but our office has not received, another copy has been requested and is in the process of being sent to our office. Once received, defendant will need additional time to have them reviewed by our medical expert and an addendum report issued and served on counsel for plaintiff. 8. It is anticipated that all of the required discovery will be completed by January 15, 2022. 9. Pursuant to R.4:24-1(c), there have been prior Orders to extend, copies of which uploaded by the Court under Trans ID LCV20211728523 on July 23, 2021. 10. There is scheduled an Arbitration hearing on November 10, 2021 which defendant respectfully requests be adjourned to allow for the discovery extension. 11. I hereby certify that the moving party is not in default of discovery. 12. I 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: October 6, 2021 ___________ Emma K Bradley CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 6 of 7 Trans ID: LCV20212329814 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 vs Civil Action VENESSA WILLIAMS, MILDRED ORDER TO EXTEND DISCOVERY AND WILLIAMS and JOHN DOE (1-unlimited) COMPEL 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 WilliamsMildred Williams; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce within ten days of the entry of the Order the clear copy of the declaration page of insurance which was previously court ordered on 5/14/2021; and IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce within 20 days of the entry of this Order the signed authorization directed to Pennsauken Diagnostic Center and a clear copy of the declaration page of insurance which was previously compelled by order dated 5/14/2021 IT IS FURTHER ORDERED that if plaintiff/s, shall fail to comply such further relief as this court may deem appropriate; and CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 7 of 7 Trans ID: LCV20212329814 IT IS FURTHER ORDERED that if plaintiff/defendant shall fail to comply with the terms of this Order, the moving party may have the right to submit an Ex Parte Affidavit requesting the dismissal of plaintiff’s/s’ Complaint/suppression of co-defendant’s/s’ Answer and Defenses; and ORDERED that the time for the completion of discovery is hereby extended to January 15, 2022; IT IS FURTHER ORDERED that the Arbitration date of 11/10/2021 is hereby adjourned to allow for the discovery extension; 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. All MRI Films to IME doctor for November 15, 2021 Addendum Report 2. Addendum Report served on adversary January 15, 2022 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 10/06/2021 4:40:23 PM Pg 1 of 2 Trans ID: LCV20212329814 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 vs Civil Action VENESSA WILLIAMS, MILDRED ORDER TO EXTEND DISCOVERY AND WILLIAMS and JOHN DOE (1-unlimited) COMPEL 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 WilliamsMildred Williams; and the Court having considered the moving papers of the parties; and for good cause shown; IT IS, on this day of , 20 ; IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce within ten days of the entry of the Order the clear copy of the declaration page of insurance which was previously court ordered on 5/14/2021; and IT IS FURTHER ORDERED, that the plaintiff be and is hereby Compelled to produce within 20 days of the entry of this Order the signed authorization directed to Pennsauken Diagnostic Center and a clear copy of the declaration page of insurance which was previously compelled by order dated 5/14/2021 IT IS FURTHER ORDERED that if plaintiff/s, shall fail to comply such further relief as this court may deem appropriate; and CAM-L-001984-20 10/06/2021 4:40:23 PM Pg 2 of 2 Trans ID: LCV20212329814 IT IS FURTHER ORDERED that if plaintiff/defendant shall fail to comply with the terms of this Order, the moving party may have the right to submit an Ex Parte Affidavit requesting the dismissal of plaintiff’s/s’ Complaint/suppression of co-defendant’s/s’ Answer and Defenses; and ORDERED that the time for the completion of discovery is hereby extended to January 15, 2022; IT IS FURTHER ORDERED that the Arbitration date of 11/10/2021 is hereby adjourned to allow for the discovery extension; 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. All MRI Films to IME doctor for November 15, 2021 Addendum Report 2. Addendum Report served on adversary January 15, 2022 IT IS FURTHER ORDERED that service of this Order shall be deemed effectuated upon all parties upon its upload to eCourts. ________________________________ , J.S.C.