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PAS-L-000200-24 01/18/2024 12:19:42 PM Pglof6 Trans ID: LCV2024153456
Andrew Venturelli, P.C.
Andrew Venturelli, Esq.
Attorney I.D.: 042381989
aventurelli@venturellilaw.com
One Howe Avenue
Passaic, NJ, 07055
Telephone No.: 1-973-365-5858
Fax No.: 1-973-365-4004
Attorney for Plaintiffs
File No.: 11362-AV
Jaime Crisolis-Lavin SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: PASSAIC COUNTY
DOCKET NO: PAS-L-
Plaintiff(s)
Civil Action
Vs.
Angel B. Abreu-Jesus and John Doe, 1-5 COMPLAINT, A.LC.R.A.
(Fictitious Names) CERTIFICATION, JURY DEMAND, &
DEMAND FOR ANSWERS TO UNIFORM
AND SUPPLEMENTAL
INTERROGATORIES
Defendant(s)
The Plaintiff Jaime Crisolis-Lavin residing at 90 Russell Street, Clifton, NJ, by way of
complaint against the Defendant Angel B. Abreu-Jesus, says:
1. On or about December 21, 2022, the Plaintiff Jaime Crisolis-Lavin was stopped at
the intersection of Palisade Avenue and Horizon Road, Fort Lee, NJ.
2. At the time and place aforesaid, the Defendant Angel B. Abreu-Jesus was the owner
and operator of a motor vehicle proceeding at the intersection of Palisade Avenue and
Horizon Road, Fort Lee, NJ. If any named party/defendant denies ownership or operation, or if
there is an unknown unidentified negligent party, or if it is alleged a defendant fled the scene,
Plaintiff substitutes John Doe, 1-5. Said name, John Doe, 1-5, stated herein fictitiously is
unknown to Plaintiff. When said true and correct name is ascertained, leave of Court will be
asked to amend the Complaint to include the true and correct name of same.
3. At the time and place aforesaid, the Defendant Angel B. Abreu-Jesus was negligent
and careless in the operation of his motor vehicle or was otherwise inattentive which negligence
and carelessness caused the vehicle of the defendant to collide with the vehicle of Plaintiff, Jaime
Crisolis-Lavin.
4. Asa direct and proximate result of the negligence and carelessness of the defendant,
as aforesaid, the Plaintiff Jaime Crisolis-Lavin was caused to sustain severe and permanent
injuries, which have caused him great pain and suffering and have prevented him from pursuing
his usual daily activities.
PAS-L-000200-24 01/18/2024 12:19:42 PM Pg2of6 Trans ID: LCV2024153456
WHEREFORE, the Plaintiff Jaime Crisolis-Lavin demands judgment against the
Defendant Angel B. Abreu-Jesus, jointly, severally or in the alternative for damages together
with interest and costs of suit.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturelli
Andrew Venturelli, Esq.
JURY DEMAND
Plaintiff demands trial by jury of six on all issues herein.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturellv
Andrew Venturelli, Esq.
CERTIFICATION
We hereby certify that the foregoing pleading has been filed within the time period set by
the applicable Court Rules and extensions thereof.
Pursuant to R. 4:5-1 we hereby certify that we have no knowledge of any other pending
actions or proceedings concerning the subject matter of this action. It is not anticipated at this
time that there is any other party who should be joined in this action.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturelli
Andrew Venturelli, Esq.
DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4:25-4, Andrew Venturelli, Esq., is hereby designated trial counsel to
the within matter on behalf of the plaintiff.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturelli
Andrew Venturelli, Esq.
PAS-L-000200-24 01/18/2024 12:19:42 PM Pg3of6 Trans ID: LCV2024153456
CERTIFICATION PURSUANT TO A.LC.R.A. OF 1999
Pursuant to the Automobile Insurance Costs Reduction Act of 1999, if the plaintiffis
bound by the limitation on lawsuit, also known as the limited right to sue, verbal, lawsuit, etc.,
the applicable certification by a physician as set forth under the Act is attached and made part of
this Complaint.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturelli
Andrew Venturelli, Esq.
DEMAND FOR ANSWERS TO UNIFORM AND SUPPLEMENTAL INTERROGATORIES
PLEASE TAKE NOTICE that pursuant to Rule 4:17-1(b)(ii)(2), Plaintiff hereby
demands answers to Uniform Interrogatories Form C, Form C(1) and Form C(2) within sixty
(60) days of the filing of Defendant’s Answer to this Complaint.
PLEASE TAKE FURTHER NOTICE that pursuant to Rule 4:17-1(b)(i)(1) and Rule
4:17-2, Plaintiff hereby demands answers to the attached Supplemental Interrogatories within
sixty (60) days of the filing of Defendant’s Answer to this Complaint.
Andrew Venturelli, P.C.
Attorneys for Plaintiff
Andrew Venturelly
Andrew Venturelli, Esq.
SUPPLEMENTAL INTERROGATORIES PERMITTED PURSUANT
TO RULE 4:17-1(b)(i)
Are you in possession of any photographs, videotapes and/or tape recordings to be used
at the time of trial.
State the names and addresses of any and all proposed expert witnesses and attach true
copies of all written reports provided to you by such proposed expert witness and the
expert witnesses curriculum vitae.
With respect to all expert witnesses, including treating physicians, who are expected to
testify at trial and with respect to any person who has conducted an examination
pursuant to Rule 4:19, who may testify, state each such witness's name, address and
area of expertise and attach a true copy of all written reports provided to you. Ifa
report is not written, supply a summary of any oral report provided to you.
If you or your expert witnesses intend to rely upon or offer into evidence any text book,
paper or authority to substantiate any opinions and conclusions or to rely upon the
PAS-L-000200-24 01/18/2024 12:19:42 PM Pg4of6 Trans ID: LCV2024153456
same in your examination or cross examination of any experts, state the exact title of
each such text book, paper or authority, the name of the author of each, the name and
address of the publisher of each and the date which each was published.
Do you have any additional insurance, i.e, umbrella policy, additional liability
coverage, etc., that may cover damages in this matter?
Did this defendant provide a statement in any form to the insurance carrier prior to
defense counsel being assigned?
Please provide the plaintiff with any and all information regarding plaintiff's
involvement, if any, in any prior motor vehicle accidents.
If these answers to interrogatories are signed by someone other than the defendant,
please provide that persons name, address, company position, anyone who helped in
answering any questions, what questions they helped answer, all documents used by
anyone in answering any question, all persons who assisted in answering the questions,
any computer screens used in answering any questions, any memos used or generated
in answering these questions and attach copies of all of these documents.
If you dispute the necessity of any medical/chiropractic care provided to the plaintiff,
or the reasonableness of the charges for that care, set forth all facts relevant to this
disputed contention.
10 Do you contend that another person was the cause of the accident that is not a party to
this action?
——_— PAS-L-000200-24 01/18/2024 12:19:42 PM Pg5 of 6 Trans ID: LCV2024153456
CERTIFICATION OF
PHYSICIAN PURSUANT
TON.J.S.A. 39:6A-8
Jaime Crisolis Lavin
i Dr. Michael Manno, certify as follows:
New Jersey and
1. [ama licensed physician (as defined in 39:6A-8a) of the State of in
Cc ‘risolis
I treated or examined the plaintiff, Criso “anes for injuries sustained
Lavin, Jaime
lis Lavin,
an accident that occurred on 12/21/2022.
ve medical
Based upon my experie: nce, my findings on examination, objecti
ive rep ort and
evidence and/or diagnostics testing as set forth in my narrat
a reasonable degree
attachments thereto, it is my professional opinion that within
in the above
of medical probability, the above patient has sustained an injury
accident which:
Diagnostic Testing Findings
06/21/2023 1 Malalignment as above.
Lumbar MRI
2. L2-L3 Level: Disc bulging mildly narrows the
neural foramina bilaterally.
3 L3-L4 Level: Dise bulging mildly narrows the
.
neural foramina bilaterally.
L4-L5 Level: Disc bulging with central annular
tear impinges upon the anterior thecal sac and
narrows the neural foramina bilaterally.
L5-S1 Level: Disc bulging impinges upon the
anterior thecal sac and narrows the neural
foramina bilaterally.
[Check all that apply]
has resulted in death
has resulted in dismemberment
has resulted in significant disfigurement or significant scarring
has caused a displaced fracture
to
is permanent- has not healed to function normally and will not heal
function normally with further medical treatment.
probability,
3. It is my further opinion that within a reasonable degree of medical
future may alleviat e some sympto matology,
that although further treatment in the
of further
the pei manent residuals of injury cannot be completely resolved by way
be some aspect of residua l
medical treatment intervention and. there will always
.
permanent injury experience for the balance of my patient’s lifetime
to the best of my
I certify that the foregoing statements made by me are true
to punishment as
knowledge, information and belief. I am aware that I am subject
PAS-L-000200-24 01/18/2024 12:19:42 PM Pg6of6 Trans ID: LCV2024153456
of the foregoing
outlined in the Automobile Insurance Cost Reduction Act if any
statements are made with fraudulent intent.
Dr. Michael Manno, D.C.
Dated: 10/21/2023
PAS-L-000200-24 01/18/2024 12:19:42 PM Pglof2 Trans ID: LCV2024153456
Civil Case Information Statement
Case Details: PASSAIC | Civil Part Docket# L-000200-24
Case Caption: CRISOLIS-LAVIN JAIME VS ABREU-JESUS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
ANGEL THRESHOLD)
Case Initiation Date: 01/18/2024 Document Type: Complaint with Jury Demand
Attorney Name: ANDREW VENTURELLI Jury Demand: YES - 6 JURORS
Firm Name: ANDREW VENTURELLI, PC Is this a professional malpractice case? NO
Address: ONE HOWE AVENUE Related cases pending: NO
PASSAIC NJ 07055 If yes, list docket numbers:
Phone: 9733655858 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Crisolis-Lavin, Jaime transaction or occurrence)? NO
Name of Defendant's Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): PROGRESSIVE FREEDOM INS CO
Are sexual abuse claims alleged by: Jaime Crisolis-Lavin? 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? YES
If yes, for what language:
SPANISH
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
Medical Debt Claim? NO
| 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)
01/18/2024 /s/ ANDREW VENTURELLI
Dated Signed
PAS-L-000200-24 01/18/2024 12:19:42 PM Pg2of2 Trans ID: LCV2024153456
Preview
PAS-L-000200-24 01/18/2024 12:19:42 PM Pglof6 Trans ID: LCV2024153456 Andrew Venturelli, P.C. Andrew Venturelli, Esq. Attorney I.D.: 042381989 aventurelli@venturellilaw.com One Howe Avenue Passaic, NJ, 07055 Telephone No.: 1-973-365-5858 Fax No.: 1-973-365-4004 Attorney for Plaintiffs File No.: 11362-AV Jaime Crisolis-Lavin SUPERIOR COURT OF NEW JERSEY LAW DIVISION: PASSAIC COUNTY DOCKET NO: PAS-L- Plaintiff(s) Civil Action Vs. Angel B. Abreu-Jesus and John Doe, 1-5 COMPLAINT, A.LC.R.A. (Fictitious Names) CERTIFICATION, JURY DEMAND, & DEMAND FOR ANSWERS TO UNIFORM AND SUPPLEMENTAL INTERROGATORIES Defendant(s) The Plaintiff Jaime Crisolis-Lavin residing at 90 Russell Street, Clifton, NJ, by way of complaint against the Defendant Angel B. Abreu-Jesus, says: 1. On or about December 21, 2022, the Plaintiff Jaime Crisolis-Lavin was stopped at the intersection of Palisade Avenue and Horizon Road, Fort Lee, NJ. 2. At the time and place aforesaid, the Defendant Angel B. Abreu-Jesus was the owner and operator of a motor vehicle proceeding at the intersection of Palisade Avenue and Horizon Road, Fort Lee, NJ. If any named party/defendant denies ownership or operation, or if there is an unknown unidentified negligent party, or if it is alleged a defendant fled the scene, Plaintiff substitutes John Doe, 1-5. Said name, John Doe, 1-5, stated herein fictitiously is unknown to Plaintiff. When said true and correct name is ascertained, leave of Court will be asked to amend the Complaint to include the true and correct name of same. 3. At the time and place aforesaid, the Defendant Angel B. Abreu-Jesus was negligent and careless in the operation of his motor vehicle or was otherwise inattentive which negligence and carelessness caused the vehicle of the defendant to collide with the vehicle of Plaintiff, Jaime Crisolis-Lavin. 4. Asa direct and proximate result of the negligence and carelessness of the defendant, as aforesaid, the Plaintiff Jaime Crisolis-Lavin was caused to sustain severe and permanent injuries, which have caused him great pain and suffering and have prevented him from pursuing his usual daily activities. PAS-L-000200-24 01/18/2024 12:19:42 PM Pg2of6 Trans ID: LCV2024153456 WHEREFORE, the Plaintiff Jaime Crisolis-Lavin demands judgment against the Defendant Angel B. Abreu-Jesus, jointly, severally or in the alternative for damages together with interest and costs of suit. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturelli Andrew Venturelli, Esq. JURY DEMAND Plaintiff demands trial by jury of six on all issues herein. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturellv Andrew Venturelli, Esq. CERTIFICATION We hereby certify that the foregoing pleading has been filed within the time period set by the applicable Court Rules and extensions thereof. Pursuant to R. 4:5-1 we hereby certify that we have no knowledge of any other pending actions or proceedings concerning the subject matter of this action. It is not anticipated at this time that there is any other party who should be joined in this action. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturelli Andrew Venturelli, Esq. DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4:25-4, Andrew Venturelli, Esq., is hereby designated trial counsel to the within matter on behalf of the plaintiff. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturelli Andrew Venturelli, Esq. PAS-L-000200-24 01/18/2024 12:19:42 PM Pg3of6 Trans ID: LCV2024153456 CERTIFICATION PURSUANT TO A.LC.R.A. OF 1999 Pursuant to the Automobile Insurance Costs Reduction Act of 1999, if the plaintiffis bound by the limitation on lawsuit, also known as the limited right to sue, verbal, lawsuit, etc., the applicable certification by a physician as set forth under the Act is attached and made part of this Complaint. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturelli Andrew Venturelli, Esq. DEMAND FOR ANSWERS TO UNIFORM AND SUPPLEMENTAL INTERROGATORIES PLEASE TAKE NOTICE that pursuant to Rule 4:17-1(b)(ii)(2), Plaintiff hereby demands answers to Uniform Interrogatories Form C, Form C(1) and Form C(2) within sixty (60) days of the filing of Defendant’s Answer to this Complaint. PLEASE TAKE FURTHER NOTICE that pursuant to Rule 4:17-1(b)(i)(1) and Rule 4:17-2, Plaintiff hereby demands answers to the attached Supplemental Interrogatories within sixty (60) days of the filing of Defendant’s Answer to this Complaint. Andrew Venturelli, P.C. Attorneys for Plaintiff Andrew Venturelly Andrew Venturelli, Esq. SUPPLEMENTAL INTERROGATORIES PERMITTED PURSUANT TO RULE 4:17-1(b)(i) Are you in possession of any photographs, videotapes and/or tape recordings to be used at the time of trial. State the names and addresses of any and all proposed expert witnesses and attach true copies of all written reports provided to you by such proposed expert witness and the expert witnesses curriculum vitae. With respect to all expert witnesses, including treating physicians, who are expected to testify at trial and with respect to any person who has conducted an examination pursuant to Rule 4:19, who may testify, state each such witness's name, address and area of expertise and attach a true copy of all written reports provided to you. Ifa report is not written, supply a summary of any oral report provided to you. If you or your expert witnesses intend to rely upon or offer into evidence any text book, paper or authority to substantiate any opinions and conclusions or to rely upon the PAS-L-000200-24 01/18/2024 12:19:42 PM Pg4of6 Trans ID: LCV2024153456 same in your examination or cross examination of any experts, state the exact title of each such text book, paper or authority, the name of the author of each, the name and address of the publisher of each and the date which each was published. Do you have any additional insurance, i.e, umbrella policy, additional liability coverage, etc., that may cover damages in this matter? Did this defendant provide a statement in any form to the insurance carrier prior to defense counsel being assigned? Please provide the plaintiff with any and all information regarding plaintiff's involvement, if any, in any prior motor vehicle accidents. If these answers to interrogatories are signed by someone other than the defendant, please provide that persons name, address, company position, anyone who helped in answering any questions, what questions they helped answer, all documents used by anyone in answering any question, all persons who assisted in answering the questions, any computer screens used in answering any questions, any memos used or generated in answering these questions and attach copies of all of these documents. If you dispute the necessity of any medical/chiropractic care provided to the plaintiff, or the reasonableness of the charges for that care, set forth all facts relevant to this disputed contention. 10 Do you contend that another person was the cause of the accident that is not a party to this action? ——_— PAS-L-000200-24 01/18/2024 12:19:42 PM Pg5 of 6 Trans ID: LCV2024153456 CERTIFICATION OF PHYSICIAN PURSUANT TON.J.S.A. 39:6A-8 Jaime Crisolis Lavin i Dr. Michael Manno, certify as follows: New Jersey and 1. [ama licensed physician (as defined in 39:6A-8a) of the State of in Cc ‘risolis I treated or examined the plaintiff, Criso “anes for injuries sustained Lavin, Jaime lis Lavin, an accident that occurred on 12/21/2022. ve medical Based upon my experie: nce, my findings on examination, objecti ive rep ort and evidence and/or diagnostics testing as set forth in my narrat a reasonable degree attachments thereto, it is my professional opinion that within in the above of medical probability, the above patient has sustained an injury accident which: Diagnostic Testing Findings 06/21/2023 1 Malalignment as above. Lumbar MRI 2. L2-L3 Level: Disc bulging mildly narrows the neural foramina bilaterally. 3 L3-L4 Level: Dise bulging mildly narrows the . neural foramina bilaterally. L4-L5 Level: Disc bulging with central annular tear impinges upon the anterior thecal sac and narrows the neural foramina bilaterally. L5-S1 Level: Disc bulging impinges upon the anterior thecal sac and narrows the neural foramina bilaterally. [Check all that apply] has resulted in death has resulted in dismemberment has resulted in significant disfigurement or significant scarring has caused a displaced fracture to is permanent- has not healed to function normally and will not heal function normally with further medical treatment. probability, 3. It is my further opinion that within a reasonable degree of medical future may alleviat e some sympto matology, that although further treatment in the of further the pei manent residuals of injury cannot be completely resolved by way be some aspect of residua l medical treatment intervention and. there will always . permanent injury experience for the balance of my patient’s lifetime to the best of my I certify that the foregoing statements made by me are true to punishment as knowledge, information and belief. I am aware that I am subject PAS-L-000200-24 01/18/2024 12:19:42 PM Pg6of6 Trans ID: LCV2024153456 of the foregoing outlined in the Automobile Insurance Cost Reduction Act if any statements are made with fraudulent intent. Dr. Michael Manno, D.C. Dated: 10/21/2023 PAS-L-000200-24 01/18/2024 12:19:42 PM Pglof2 Trans ID: LCV2024153456 Civil Case Information Statement Case Details: PASSAIC | Civil Part Docket# L-000200-24 Case Caption: CRISOLIS-LAVIN JAIME VS ABREU-JESUS Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL ANGEL THRESHOLD) Case Initiation Date: 01/18/2024 Document Type: Complaint with Jury Demand Attorney Name: ANDREW VENTURELLI Jury Demand: YES - 6 JURORS Firm Name: ANDREW VENTURELLI, PC Is this a professional malpractice case? NO Address: ONE HOWE AVENUE Related cases pending: NO PASSAIC NJ 07055 If yes, list docket numbers: Phone: 9733655858 Do you anticipate adding any parties (arising out of same Name of Party: PLAINTIFF : Crisolis-Lavin, Jaime transaction or occurrence)? NO Name of Defendant's Primary Insurance Company Does this case involve claims related to COVID-19? NO (if known): PROGRESSIVE FREEDOM INS CO Are sexual abuse claims alleged by: Jaime Crisolis-Lavin? 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? YES If yes, for what language: SPANISH Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO Medical Debt Claim? NO | 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) 01/18/2024 /s/ ANDREW VENTURELLI Dated Signed PAS-L-000200-24 01/18/2024 12:19:42 PM Pg2of2 Trans ID: LCV2024153456