Preview
CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 1 of 7 Trans ID: LCV20233125480
Law Office
of
DEBRA HART
DEBRA HART ++ EVAN C. CAMHI+
581 MAIN STREET
CATHERINE MASTERSON NATALIE O. MATLA+++
SUITE 300
EMMA K. BRADLEY++ ELIZABETH DARMODY++
WOODBRIDGE, NJ 07095
STEVEN I. GREENBERG (732) 378-4600 HAROLD WEST
ANTHONY F. BELOTTA Fax: (732) 378-4426
Employees of Palisades/High Point Insurance Group + NJ & NY BARS
++ NJ & PA BARS
+++ NJ NY PA 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 16, 2023
Camden County Superior Court
101 South Fifth Street
Camden, NJ 08103
Re: Jones vs Presnall
Our File No:681102021011
Docket No: CAM-L-2481-23
Dear Sir/Madam:
Enclosed please find documents as listed below:
(X) Answer
(X) Civil Case Information Statement
Kindly:
(X) Charge the filing fee to Collateral Acct: 144293
(X) File
Very truly yours,
Emma K Bradley, Esq.
EKB/kf
cc: Marguerite Toye/Parsippany Claims Office/681102021011
Michael Foster Esq
CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 2 of 7 Trans ID: LCV20233125480
Emma K Bradley – 129492014
DEBRA HART
581 MAIN STREET
SUITE 300
WOODBRIDGE NJ 07095
(732) 378-4600
FAX: (732) 378-4426
Attorney for Defendant, Dolores Presnall
Robert Jones SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CAMDEN COUNTY
Plaintiff DOCKET NO.CAM-L-2481-23
vs Civil Action
Dolores Presnall and John Does 1-10 ANSWER AND JURY DEMAND
(fictitious designations)
Defendant.
The Defendant, Dolores Presnall, by way of Answer to the Complaint filed by the Plaintiff, say/s:
FIRST COUNT
1. The defendant has insufficient knowledge of the facts alleged in the first paragraph and thus
leaves plaintiff to his proofs
2. The defendant has insufficient knowledge of the facts alleged in the second paragraph and thus
leaves plaintiff to his proofs
3. As none of the allegations set forth in the third paragraph pertain to this defendant, no answer is
supplied. However, where they may be deemed to apply to this defendant, said allegations are
denied.
4. The defendant denies the allegations set forth in the fourth paragraph.
5. The defendant denies the allegations set forth in the fifth paragraph.
WHEREFORE, this Defendant demand/s judgment dismissing Plaintiff’s Complaint.
SECOND COUNT
1. The defendant repeat/s each of her answers to each of the allegations set forth in the First Count/s
of the Complaint, and make/s the same a part hereof as if fully set forth herein.
2. The defendant denies the allegations set forth in the second paragraph.
WHEREFORE, this Defendant demand/s judgment dismissing Plaintiff’s Complaint.
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AFFIRMATIVE DEFENSES
FIRST SEPARATE DEFENSE
The Plaintiff was guilty of contributory negligence and such negligence was greater than the negligence
of this Defendant. In the event such contributory negligence is adjudged to be not greater than the
negligence of this Defendant, this Defendant demand/s 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 this Defendant
had no control.
THIRD SEPARATE DEFENSE
The damages of the Claimant/s, if any, are as limited by the applicable laws of the State of New Jersey
as respects comparative negligence.
FOURTH SEPARATE DEFENSE
Plaintiff, by her own actions and form of conduct, has waived any and all claims that he/she/they has
against this Defendant.
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
This Defendant was guilty of no negligence which was a proximate cause of the injuries and damages
alleged.
SEVENTH SEPARATE DEFENSE
Plaintiff’s Complaint is defective and subject to dismissal by reason of its failures to join indispensable
parties to this action.
EIGHTH SEPARATE DEFENSE
Plaintiff’s claim/s is barred by the Entire Controversy Doctrine.
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NINTH SEPARATE DEFENSE
The Claimant/s assumed the risk and was fully cognizant of any and all circumstances surrounding the
alleged incident.
TENTH SEPARATE DEFENSE
The claim/s of the Plaintiff cannot be superior to that of her assignor and since the assignor’s/s’ claim/s
is barred, the Plaintiff’s claim/s is also barred.
ELEVENTH SEPARATE DEFENSE
This Defendant neither owed a duty to the Plaintiff, nor did he/she/they violate any duty which may be
found to have been owing to the Plaintiff.
TWELFTH SEPARATE DEFENSE
The Complaint herein fails to state a claim upon which relief can be granted and this Defendant
reserve/s the right to move at or before the time of trial to dismiss same.
THIRTEENTH 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/s is barred from recovery as a matter of law because
the alleged claim/s 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.
FOURTEENTH 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/s and, accordingly, the Claimant’s/s’ claim/s is barred as a matter of
law.
FIFTEENTH SEPARATE DEFENSE
The Defendant reserve/s 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 ten (10) days after the filing of the Complaint as
required by R. 4:4-1.
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SIXTEENTH SEPARATE DEFENSE
Plaintiff has executed a valid and binding Release by the terms, effect and operation of which Plaintiff
has released this Defendant from liability to Plaintiff for the incident and damages complained of.
SEVENTEENTH SEPARATE DEFENSE
The Plaintiff’s claim/s asserted in this action was the subject of earlier litigation and judicial
determination and Plaintiff’s claim/s is collateral estopped and/or barred by reason of the Doctrine of
Res Adjudicata.
EIGHTEENTH SEPARATE DEFENSE
This Defendant allege/s that the claim/s for damages asserted by Plaintiff’s Complaint has been paid
and satisfied and therefore, was in accord and satisfaction of all claims.
NINETEENTH SEPARATE DEFENSE
Plaintiff has failed to mitigate damages.
TWENTIETH SEPARATE DEFENSE
Pursuant to R. 4:3-2 and/or to the Doctrine of Forum Non Conveniens, venue in this jurisdiction is
improper.
TWENTY-FIRST SEPARATE DEFENSE
There is a lack of jurisdiction over the Defendant by reason of insufficiency of process and
insufficiency of service of process.
TWENTY-SECOND SEPARATE DEFENSE
Defendant raise/s and is entitled to the benefits of the Collateral Source Statute, N.J.S.A. 2A:15-97.
TWENTY-THIRD SEPARATE DEFENSE
Plaintiff has failed to maintain medical expense benefits as mandated by N.J.S.A. 39:6A-4 and
therefore, her claim/s is barred by N.J.S.A. 39:6A-4.5.
DEMAND FOR ALLOCATION PURSUANT TO R. 4:7-5(c)
If any Defendant settles with the Plaintiff prior to trial, this Defendant will seek an allocation by the
jury of the percentage of negligence against the settling Defendant. This Defendant will seek this
allocation, whether or not this Defendant has formally filed a crossclaim against the settling
CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 6 of 7 Trans ID: LCV20233125480
Defendant. This Defendant will rely upon the direct cross-examination of all witnesses at trial in
support of this allocation. This demand is made pursuant to R. 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 party/ies filing this Answer require/s 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.
DEMAND FOR TRIAL BY JURY
PLEASE TAKE NOTICE that this Defendant 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 party/ies filing this Answer require/s that
Plaintiff provide answers to Uniform Interrogatories set forth in Form A of Appendix II as amended
effective September 1, 2022.
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
By: ___________
Emma K Bradley, Esq.
Attorney for Defendant
Dated: October 16, 2023
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CERTIFICATION OF MAILING
I hereby certify that the original of the within document has been eFiled 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.
Law Office of Debra Hart
By: ___________
Emma K Bradley, Esq.
Attorney for Defendant
Dated: October 16, 2023
CAM-L-002481-23 10/16/2023
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12:17:54PM
PM Pg 1 of 1 Trans
TransID:
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Civil Case Information Statement
Case Details: CAMDEN | Civil Part Docket# L-002481-23
Case Caption: JONES ROBERT VS PRESNALL Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
DOLORES THRESHOLD)
Case Initiation Date: 08/29/2023 Document Type: Answer W/Jury Demand
Attorney Name: EMMA KRISTINE BRADLEY Jury Demand: YES - 12 JURORS
Firm Name: PLYMOUTH ROCK ASSURANCE CO Is this a professional malpractice case? NO
Address: 581 MAIN STREET SUITE 300 Related cases pending: NO
WOODBRIDGE NJ 07095 If yes, list docket numbers:
Phone: 7323784600 Do you anticipate adding any parties (arising out of same
Name of Party: DEFENDANT : PRESNALL, DOLORES transaction or occurrence)? NO
Name of Defendant’s Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): PALISADES SAFETY & INS ASSOC
Are sexual abuse claims alleged by: ROBERT JONES? 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)
10/16/2023 /s/ EMMA KRISTINE BRADLEY
Dated Signed
Preview
CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 1 of 7 Trans ID: LCV20233125480 Law Office of DEBRA HART DEBRA HART ++ EVAN C. CAMHI+ 581 MAIN STREET CATHERINE MASTERSON NATALIE O. MATLA+++ SUITE 300 EMMA K. BRADLEY++ ELIZABETH DARMODY++ WOODBRIDGE, NJ 07095 STEVEN I. GREENBERG (732) 378-4600 HAROLD WEST ANTHONY F. BELOTTA Fax: (732) 378-4426 Employees of Palisades/High Point Insurance Group + NJ & NY BARS ++ NJ & PA BARS +++ NJ NY PA 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 16, 2023 Camden County Superior Court 101 South Fifth Street Camden, NJ 08103 Re: Jones vs Presnall Our File No:681102021011 Docket No: CAM-L-2481-23 Dear Sir/Madam: Enclosed please find documents as listed below: (X) Answer (X) Civil Case Information Statement Kindly: (X) Charge the filing fee to Collateral Acct: 144293 (X) File Very truly yours, Emma K Bradley, Esq. EKB/kf cc: Marguerite Toye/Parsippany Claims Office/681102021011 Michael Foster Esq CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 2 of 7 Trans ID: LCV20233125480 Emma K Bradley – 129492014 DEBRA HART 581 MAIN STREET SUITE 300 WOODBRIDGE NJ 07095 (732) 378-4600 FAX: (732) 378-4426 Attorney for Defendant, Dolores Presnall Robert Jones SUPERIOR COURT OF NEW JERSEY LAW DIVISION: CAMDEN COUNTY Plaintiff DOCKET NO.CAM-L-2481-23 vs Civil Action Dolores Presnall and John Does 1-10 ANSWER AND JURY DEMAND (fictitious designations) Defendant. The Defendant, Dolores Presnall, by way of Answer to the Complaint filed by the Plaintiff, say/s: FIRST COUNT 1. The defendant has insufficient knowledge of the facts alleged in the first paragraph and thus leaves plaintiff to his proofs 2. The defendant has insufficient knowledge of the facts alleged in the second paragraph and thus leaves plaintiff to his proofs 3. As none of the allegations set forth in the third paragraph pertain to this defendant, no answer is supplied. However, where they may be deemed to apply to this defendant, said allegations are denied. 4. The defendant denies the allegations set forth in the fourth paragraph. 5. The defendant denies the allegations set forth in the fifth paragraph. WHEREFORE, this Defendant demand/s judgment dismissing Plaintiff’s Complaint. SECOND COUNT 1. The defendant repeat/s each of her answers to each of the allegations set forth in the First Count/s of the Complaint, and make/s the same a part hereof as if fully set forth herein. 2. The defendant denies the allegations set forth in the second paragraph. WHEREFORE, this Defendant demand/s judgment dismissing Plaintiff’s Complaint. CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 3 of 7 Trans ID: LCV20233125480 AFFIRMATIVE DEFENSES FIRST SEPARATE DEFENSE The Plaintiff was guilty of contributory negligence and such negligence was greater than the negligence of this Defendant. In the event such contributory negligence is adjudged to be not greater than the negligence of this Defendant, this Defendant demand/s 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 this Defendant had no control. THIRD SEPARATE DEFENSE The damages of the Claimant/s, if any, are as limited by the applicable laws of the State of New Jersey as respects comparative negligence. FOURTH SEPARATE DEFENSE Plaintiff, by her own actions and form of conduct, has waived any and all claims that he/she/they has against this Defendant. 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 This Defendant was guilty of no negligence which was a proximate cause of the injuries and damages alleged. SEVENTH SEPARATE DEFENSE Plaintiff’s Complaint is defective and subject to dismissal by reason of its failures to join indispensable parties to this action. EIGHTH SEPARATE DEFENSE Plaintiff’s claim/s is barred by the Entire Controversy Doctrine. CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 4 of 7 Trans ID: LCV20233125480 NINTH SEPARATE DEFENSE The Claimant/s assumed the risk and was fully cognizant of any and all circumstances surrounding the alleged incident. TENTH SEPARATE DEFENSE The claim/s of the Plaintiff cannot be superior to that of her assignor and since the assignor’s/s’ claim/s is barred, the Plaintiff’s claim/s is also barred. ELEVENTH SEPARATE DEFENSE This Defendant neither owed a duty to the Plaintiff, nor did he/she/they violate any duty which may be found to have been owing to the Plaintiff. TWELFTH SEPARATE DEFENSE The Complaint herein fails to state a claim upon which relief can be granted and this Defendant reserve/s the right to move at or before the time of trial to dismiss same. THIRTEENTH 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/s is barred from recovery as a matter of law because the alleged claim/s 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. FOURTEENTH 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/s and, accordingly, the Claimant’s/s’ claim/s is barred as a matter of law. FIFTEENTH SEPARATE DEFENSE The Defendant reserve/s 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 ten (10) days after the filing of the Complaint as required by R. 4:4-1. CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 5 of 7 Trans ID: LCV20233125480 SIXTEENTH SEPARATE DEFENSE Plaintiff has executed a valid and binding Release by the terms, effect and operation of which Plaintiff has released this Defendant from liability to Plaintiff for the incident and damages complained of. SEVENTEENTH SEPARATE DEFENSE The Plaintiff’s claim/s asserted in this action was the subject of earlier litigation and judicial determination and Plaintiff’s claim/s is collateral estopped and/or barred by reason of the Doctrine of Res Adjudicata. EIGHTEENTH SEPARATE DEFENSE This Defendant allege/s that the claim/s for damages asserted by Plaintiff’s Complaint has been paid and satisfied and therefore, was in accord and satisfaction of all claims. NINETEENTH SEPARATE DEFENSE Plaintiff has failed to mitigate damages. TWENTIETH SEPARATE DEFENSE Pursuant to R. 4:3-2 and/or to the Doctrine of Forum Non Conveniens, venue in this jurisdiction is improper. TWENTY-FIRST SEPARATE DEFENSE There is a lack of jurisdiction over the Defendant by reason of insufficiency of process and insufficiency of service of process. TWENTY-SECOND SEPARATE DEFENSE Defendant raise/s and is entitled to the benefits of the Collateral Source Statute, N.J.S.A. 2A:15-97. TWENTY-THIRD SEPARATE DEFENSE Plaintiff has failed to maintain medical expense benefits as mandated by N.J.S.A. 39:6A-4 and therefore, her claim/s is barred by N.J.S.A. 39:6A-4.5. DEMAND FOR ALLOCATION PURSUANT TO R. 4:7-5(c) If any Defendant settles with the Plaintiff prior to trial, this Defendant will seek an allocation by the jury of the percentage of negligence against the settling Defendant. This Defendant will seek this allocation, whether or not this Defendant has formally filed a crossclaim against the settling CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 6 of 7 Trans ID: LCV20233125480 Defendant. This Defendant will rely upon the direct cross-examination of all witnesses at trial in support of this allocation. This demand is made pursuant to R. 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 party/ies filing this Answer require/s 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. DEMAND FOR TRIAL BY JURY PLEASE TAKE NOTICE that this Defendant 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 party/ies filing this Answer require/s that Plaintiff provide answers to Uniform Interrogatories set forth in Form A of Appendix II as amended effective September 1, 2022. 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 By: ___________ Emma K Bradley, Esq. Attorney for Defendant Dated: October 16, 2023 CAM-L-002481-23 10/16/2023 12:18:25 PM Pg 7 of 7 Trans ID: LCV20233125480 CERTIFICATION OF MAILING I hereby certify that the original of the within document has been eFiled 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. Law Office of Debra Hart By: ___________ Emma K Bradley, Esq. Attorney for Defendant Dated: October 16, 2023 CAM-L-002481-23 10/16/2023 CAM-L-002481-23 10/16/202312:18:25 12:17:54PM PM Pg 1 of 1 Trans TransID: ID:LCV20233125480 LCV20233125480 Civil Case Information Statement Case Details: CAMDEN | Civil Part Docket# L-002481-23 Case Caption: JONES ROBERT VS PRESNALL Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL DOLORES THRESHOLD) Case Initiation Date: 08/29/2023 Document Type: Answer W/Jury Demand Attorney Name: EMMA KRISTINE BRADLEY Jury Demand: YES - 12 JURORS Firm Name: PLYMOUTH ROCK ASSURANCE CO Is this a professional malpractice case? NO Address: 581 MAIN STREET SUITE 300 Related cases pending: NO WOODBRIDGE NJ 07095 If yes, list docket numbers: Phone: 7323784600 Do you anticipate adding any parties (arising out of same Name of Party: DEFENDANT : PRESNALL, DOLORES transaction or occurrence)? NO Name of Defendant’s Primary Insurance Company Does this case involve claims related to COVID-19? NO (if known): PALISADES SAFETY & INS ASSOC Are sexual abuse claims alleged by: ROBERT JONES? 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) 10/16/2023 /s/ EMMA KRISTINE BRADLEY Dated Signed