Motion to Extend Discovery Cut-Off Date in Perez Jose Vs Spivack Wendy| Trellis.Law

On July 16, 2020 a Motion,Ex Parte was filed involving a dispute between Jose Perez, and Robert Spivack, Wendy Spivack, for Personal Injury in the District Court of Camden County.

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CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 1 of 3 Trans ID: LCV20211479766

LAW OFFICES OF IBRAHIM AND JACKSON
BY: G. Samuel Hoffman, Esq.
Attorney ID: 034362006
PO Box 6835
Scranton, PA 18505-6835
856-596-7778
Attorneys for Defendant(s), Wendy Spivack and Robert Spivack

Plaintiff: SUPERIOR COURT OF NEW JERSEY
JOSE PEREZ, LAW DIVISION: CAMDEN COUNTY
DOCKET NO.: CAM-L-2424-20
vs. *
CIVIL ACTION
Defendants: *
WENDY SPIVACK and ROBERT SPIVACK. NOTICE OF MOTION TO EXTEND
DISCOVERY

TO: Marc Sigal Esq.
1528 Walnut Street
Suite 700
Philadelphia, PA 19102
Attorney for Plaintiff(s)

PLEASE TAKE NOTICE that on Friday, July 09, 2021, at 9:00 o'clock in the forenoon or
as soon thereafter as counsel may be heard, the undersigned, attorney for Defendant(s), Wendy
Spivack and Robert Spivack, shall apply before the Superior Court of New Jersey, Law Division,
before such Judge as may then be sitting, for an Order to Extend Discovery.
Defendant(s) will rely upon the attached Certification.
The undersigned hereby waives oral argument and consents to its disposition on the papers
unless opposition is filed.
A proposed Form of Order is attached hereto.

Law Offices of Ibrahim and Jackson
Attorney for Defendant(s),
Wendy Spivack and Robert Spivack

BY:______ ___________
G. Samuel Hoffman, Esq.
Dated: June 21, 2021
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 2 of 3 Trans ID: LCV20211479766

LIST OF DATES
(Appropriate Boxes Checked, and Date Given if Applicable)

[ ] Arbitration Date:

[ ] Calendar Call Date:

[ ] Trial Date:

[x] Discovery End Date: 07/19/2021

[ ] This case has been assigned neither a Pretrial Conference Date, Calendar Call Date,
nor a Trial Date.
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 3 of 3 Trans ID: LCV20211479766

Law Offices of Ibrahim and Jackson
BY: G. Samuel Hoffman, Esq.
Attorney ID: 034362006
PO Box 6835
Scranton, PA 18505-6835
856-596-7778
Attorneys for Defendant(s), Wendy Spivack and Robert Spivack

Plaintiff: SUPERIOR COURT OF NEW JERSEY
JOSE PEREZ, LAW DIVISION: CAMDEN COUNTY
DOCKET NO.: CAM-L-2424-20
vs. *
CIVIL ACTION
Defendants: *
WENDY SPIVACK and ROBERT SPIVACK. CERTIFICATION OF SERVICE

I, Judith Strater, hereby certify that:

1. I am an assistant in the Law Offices of Ibrahim and Jackson, 701A Route 73
South, Suite 420, Marlton Executive Park, 4th Floor, Marlton, NJ 08053.
2. On the 21st day of June, 2021, I electronically filed this motion. At that time I
confirmed that the parties listed below were registered for electronic service. If any of the
parties listed below are/were not registered for electronic service, I mailed a copy of the
within motion via regular mail to:

Marc Sigal, Esq.
Stanshine & Sigal, P.C.
1528 Walnut Street
Suite 700
Philadelphia, PA 19102
Attorney for Plaintiff(s)

/s/ Judith Strater
____________________________________
Judith Strater
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 1 of 1 Trans ID: LCV20211479766

LAW OFFICES OF IBRAHIM AND JACKSON
BY: G. Samuel Hoffman, Esq.
Attorney ID: 034362006
PO Box 6835
Scranton, PA 18505-6835
856-596-7778
Attorneys for Defendant(s), Wendy Spivack and Robert Spivack

Plaintiff: SUPERIOR COURT OF NEW JERSEY
JOSE PEREZ, LAW DIVISION: CAMDEN COUNTY
DOCKET NO.: CAM-L-2424-20
vs. *
CIVIL ACTION
Defendants: *
WENDY SPIVACK and ROBERT SPIVACK. ORDER TO EXTEND DISCOVERY

The above matter having been brought before the Court upon motion, with consent of all

parties, by the Law Offices of Ibrahim and Jackson, G. Samuel Hoffman, attorney for Defendant(s),

Wendy Spivack and Robert Spivack, for an Order to Extend Discovery and the court having

considered the motion papers filed by the parties, and good cause thus having been shown,

IT IS, on this day of , 2021;

ORDERED, that discovery be extended ninety (90) days or until October 17, 2021; and

IT IS FURTHER ORDERED that the parties are to complete all discovery listed below:

1. Plaintiff’s independent medical examinations to be completed by September 08, 2021, as

scheduled;

2. Any and all independent medical examination reports and addenda to be supplied by

October 13, 2021;

IT IS FURTHER ORDERED, that a copy of this order shall be deemed served upon all

counsel via e-courts.

____________________________________
J.S.C.
Opposed _______
Unopposed _______
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 1 of 5 Trans ID: LCV20211479766

LAW OFFICES OF IBRAHIM AND JACKSON
BY: G. Samuel Hoffman, Esq.
Attorney ID: 034362006
PO Box 6835
Scranton, PA 18505-6835
856-596-7778
Attorneys for Defendant(s), Wendy Spivack and Robert Spivack

Plaintiff: SUPERIOR COURT OF NEW JERSEY
JOSE PEREZ, LAW DIVISION: CAMDEN COUNTY
DOCKET NO.: CAM-L-2424-20
vs. *
CIVIL ACTION
Defendants: *
WENDY SPIVACK and ROBERT SPIVACK. CERTIFICATION IN SUPPORT OF
MOTION TO EXTEND DISCOVERY

I, G. Samuel Hoffman, Esquire, of full age, hereby certify as follows:

1. I am an Attorney at Law associated with the Law Offices of Ibrahim and Jackson,

attorney for Defendant(s), Wendy Spivack and Robert Spivack in the above matter and as such I am

fully familiar with the facts of this case.

2. The original discovery end date was extended by consent of all parties to July 19, 2021.

3. Written discovery has been exchanged and depositions have been held. However, despite

the best efforts of Counsel, discovery remains incomplete.

4. Specifically, Plaintiff appeared for the independent medical examination on May 27, 2021

with Dr. Schmidt.

5. However, it was determined that an interpreter was necessary in order for the examination

to move forward.

6. The examination was rescheduled to September 08, 2021 at 2:00 PM with Dr. Schmidt.

(See notice, attached hereto as Exhibit “A”)

7. After the independent medical examination takes place, it will be necessary for Defendants

to make certain the defense medical examiner has all relevant medical records in order to complete

the independent medical examination report. This report must be served before moving to a

possible resolution.
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 2 of 5 Trans ID: LCV20211479766

8. Without conducting the proper discovery, defendant(s) will be unable to properly defend

this matter.

9. It is for the foregoing reasons that the undersigned respectfully requests a ninety (90) day

extension on discovery.

10. My office contacted my adversary by telephone on June 17, 2021 and they consent to the

discovery extension.

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.

Law Offices of Ibrahim and Jackson
Attorney for Defendant(s),
Wendy Spivack and Robert Spivack

G. Samuel Hoffman, Esq.
Dated: June 21, 2021
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 3 of 5 Trans ID: LCV20211479766

EXHIBIT A
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 4 of 5 Trans ID: LCV20211479766

ALPHONSO H. IBRAHIM* LAW OFFICES OF MARIO C. COLITTI*
LEWIS K. JACKSON WILLIAM L. BRACAGLIA
ANDRES VEGA**
ROBERT McGRATH
IBRAHIM and JACKSON DANIEL KAYE**
MICHAEL J. PALMA ++
DENISE FOLIO TUNNEY* Not a Partnership EMILY S. BARNETT**
SEAN D. CASCIO* Employees of Liberty Mutual Group, Inc. LYNN HERSHKOVITS-GOLDBERG
DOMINICK FIORELLO PATRICIA R. LYONS
JOHN J. MASTRONARDI* CHRISTOPHER M. KOLB**
G. SAMUEL HOFFMAN* Mailing Address NICOLE L. HOLLINGSWORTH****
MICHAEL R. BUSTARD* MICHAEL A. ROTER **
SUNGKYU S. LEE***
PO Box 6835 CLIFFORD J. GIANTONIO
JENNIFER L. DRYER* Scranton, PA 18505-6835 MARY CHEN**
JULIE H. ROBINSON* LISA R. MARSHALL**
JOANNA M. INGLESSIS HILLARY C. KRUGER
CATHERINE A. SCHMUTZ* PHYSICAL ADDRESS WILLIAM F. SWEENEY*
DOUGLAS J. NOSKO* 701A ROUTE 73 SOUTH, SUITE 420 MOIRA T. DILLAWAY**
TONI M. GHEEN* JASON B. LEVOY**
LAURA M. GIFFORD* MARLTON EXECUTIVE PARK, 4TH FLOOR KIM L. MICHAELS*
ADA SACHTER GALLICCHIO* MARLTON, NJ 08053 JENNA GOUGH
FRANK R. GERBER** MANUEL DIAZ
STACEY A. SUBRYAN** JUNG CHOI
JOHN H. LAW III Telephone (856) 596-7778 BENEDICT F. VALLIERE
FAX (866) 772-9418 DINA YOUNES

*ADMITTED NJ & PA Worker’s Comp. Dept. FAX (603) 334-7199
**ADMITTED NJ & NY
*** ADMITTED NJ, PA & NY
****ADMITTED NJ, NY & DC
We are a paperless office. Send documents to email below.
CERTIFIED BY THE SUPREME COURT OF Liability: Ibrahimmail@libertymutual.com
NEW JERSEY AS A CIVIL TRIAL ATTORNEY WC: Marlton_WC@libertymutual.com
++ADMITTED NJ, NY, PA & CERTIFIED BY
THE SUPREME COURT OF NJ AS A CIVIL PIP: Ibrahim.pip@libertymutual.com
TRIAL ATTORNEY CD: IbrahimCD@libertymutual.com

G. Samuel Hoffman, Esq.
Direct Dial: (856) 355-4214
g.samuel.hoffman@libertymutual.com
June 21, 2021
Marc Sigal, Esq.
Stanshine & Sigal, P.C.
1528 Walnut Street
Suite 700
Philadelphia, PA 19102
Sent via E-mail: SNSLAW@MYLEGALGROUP.COM

RE: PEREZ vs. SPIVACK, et al.
DOCKET NO: CAM-L-2424-20
OUR FILE NO.: LA359-038303908-0004

Dear Counsel:

Please be advised that an independent medical examination of your client, Jose Perez, has been
scheduled for September 8, 2021 at 2:00 PM, with Richard G. Schmidt M.D., 1030 Kings
Highway North, Suite 200 Cherry Hill, NJ 08034. **Kindly advise if your client(s) is in need
of an interpreter.**

I would be most appreciative if you would kindly impress upon your client the importance of
attending this examination and to bring with them any and all MRI's, CT Scans, films, etc.

If your client is unable to keep this appointment, please contact my office at least 72 hours in
advance to cancel and reschedule same.

Please note that should your client fail to attend, we shall look to you for reimbursement of any "no
show" fees assessed. In addition, should you or your client cancel the appointment less than 72
hours before the scheduled time, we shall look to you for reimbursement of any cancellation fees.
CAM-L-002424-20 06/21/2021 12:38:20 PM Pg 5 of 5 Trans ID: LCV20211479766

Thank you for your attention to this matter.

Very truly yours,

G. Samuel Hoffman, Esq.
GSH/ts

Case Info

Judge

Steven J Polansky Track Judge’s New Case

Case No.

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Document Filed Date

June 21, 2021

Case Filing Date

July 16, 2020

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Motion,Ex Parte: Perez Jose Vs Spivack Wendy

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