Preview
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 1 of 5 Trans ID: LCV2024189349
Law Office of Daniel Santiago, LLC
Daniel Santiago, Esq. – 021212006
Allison R. Ramelson-Kert, Esq. - 411282022
695 U.S. 46 Suite 301C
Fairfield, New Jersey 07004
P (973) 777-9700
F (973) 546-3749
Attorneys for Plaintiffs
LISETT GONZALEZ-ROSARIO and Superior Court of New Jersey
LIDIANA GONZALEZ-ROSARIO,
Law Division: Passaic County
Plaintiff,
Docket: PAS-L-
vs
CIVIL ACTION
NYESHA GREEN, NEW JERSEY TRANSIT
CORPORATION, JOHN DOES 1-10
(Being a fictitious name), and
COMPLAINT, DESIGNATION OF TRIAL
ABC CORPORATION (being a
COUNSEL, AND JURY DEMAND
fictitious entity).
Defendants
Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-ROSARIO,
by the way of Complaint against the above Defendants, says:
FIRST COUNT
1. On or about March 9, 2022, Plaintiff, LISETT GONZALEZ-ROSARIO and
LIDIANA GONZALEZ-ROSARIO, at approximately 8:13 A.M. were
travelling southbound on Main Avenue. Plaintiffs were stopped at
the intersection of Main Avenue and Monroe Street at a red traffic
light signal, when a vehicle negligently failed to stop at the red
light and collided into Plaintiffs’ vehicle.
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 2 of 5 Trans ID: LCV2024189349
2. The vehicle which struck Plaintiff’s car, was owned by New Jersey
Transit Corporations, and operated by Defendant Nyesha Green.
3. Upon information and belief, at all times relevant to this
complaint, Nyesha Green was acting as a servant, agent, or employee
of NJ Transit.
4. As a result of Defendants’ negligence, Plaintiff was severely and
permanently insured, suffered great pain and mental anguish,
required and in the future, will require medical care and
attention, was and in the future, will be compelled to expend large
sums of money for said medical care and attention and was and in
the future, will be prevented from engaging in her normal pursuits
and occupations.
WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA
GONZALEZ-ROSARIO, demands judgment against the Defendant for damages,
together with interest and cost of suit.
SECOND COUNT
1. Plaintiff repeats and realleges each allegation made forth in the
First Count as though fully set forth at length herein.
2. At the same time and place, Defendants, John Does 1-10, were the
operators and owners of the vehicles which were owned, operated,
and maintained in a careless, reckless, and negligent manner.
3. As a result of Defendants’ negligence, Plaintiff was severely and
permanently insured, suffered great pain and mental anguish,
required and in the future, will require medical care and
attention, was and in the future, will be compelled to expend large
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 3 of 5 Trans ID: LCV2024189349
sums of money for said medical care and attention and was and in
the future, will be prevented from engaging in her normal pursuits
and occupations.
WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-
ROSARIO, demands judgment against the defendants for damages, together
with interest and cost of suit.
THIRD COUNT
1. Plaintiff repeats and realleges each allegation made forth in the
First Count as though fully set forth at length herein.
2. At the same time and place, Defendants, ABC Corporation, were the
operators and owners of the vehicles which were owned, operated,
and maintained in a careless, reckless, and negligent manner.
3. As a result of Defendants’ negligence, Plaintiff was severely and
permanently insured, suffered great pain and mental anguish,
required and in the future, will require medical care and
attention, was and in the future, will be compelled to expend large
sums of money for said medical care and attention and was and in
the future, will be prevented from engaging in her normal pursuits
and occupations.
WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-
ROSARIO, demands judgment against the defendants for damages, together
with interest and cost of suit.
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 4 of 5 Trans ID: LCV2024189349
JURY DEMAND
PLEASE TAKE NOTICE that Plaintiff demands a trial of the issues by
jury.
DESIGNATION OF TRIAL COUNSEL
Pursuant to the Rules of Court 4:25-4, the Court is hereby advised
that Daniel Santiago, Esq. is hereby designated as trial counsel in the
within matter.
DEMAND FOR DISCOVERY
Plaintiff demands that Defendant answer Form C and C (1)
Interrogatories located in the New Jersey Court Rules, Appendix II,
pursuant to R. 4:17 in a manner and within time prescribed by the Rules
of the Court.
DEMAND FOR DOCUMENT PRODUCTION
Plaintiff demands that Defendants produce any document or paper
referred to in plaintiff’s Complaint, pursuant to R.4:18-2 in a manner
and within the time frame prescribed by the Rules of Court.
NOTICE PURSUANT TO RULE 1:5-1
PLEASE TAKE NOTICE that the undersigned attorneys do hereby demand,
pursuant to the above cited Rules of Court, that each party herein
serving pleadings and interrogatories and serving answers thereto, serve
copies of all such pleadings and answered interrogatories and all
supplements, papers and other material referred to therein, received
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 5 of 5 Trans ID: LCV2024189349
from any party, upon the undersigned attorneys, and TAKE NOTICE that
this is a CONTINUING demand.
CERTIFICATION PURSUANT TO RULE 4:5-1
The undersigned is presently unaware of any Court or arbitration
proceeding which is presently pending and which relates to the matter
in controversy, and none is contemplated by the undersigned.
The undersigned is presently unaware of any other party who should
be joined in this action. I hereby 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.
Dated: January 23, 2024 By:__________________________
Daniel Santiago, Esq.,
CERTIFICATION OF FILING AND SERVICE
It is hereby certified that a copy of the Complaint has been filed
with the Clerk of in the New Jersey Superior Court in Passaic County,
and that copies have been served upon all parties within the time
provided by the Rules of Court.
Dated: January 23, 2024 By:__________________________
Daniel Santiago, Esq.
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AM Pg 1 of 2 Trans
TransID:
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LCV2024189349
Civil Case Information Statement
Case Details: PASSAIC | Civil Part Docket# L-000241-24
Case Caption: GONZALEZ-ROSARIO LISETT VS GREEN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
NYESHA VERBAL THRESHOLD)
Case Initiation Date: 01/23/2024 Document Type: Complaint with Jury Demand
Attorney Name: DANIEL SANTIAGO Jury Demand: YES - 6 JURORS
Firm Name: DANIEL SANTIAGO Is this a professional malpractice case? NO
Address: 695 US-46 STE 301 C Related cases pending: NO
FAIRFIELD NJ 07004 If yes, list docket numbers:
Phone: 9737779700 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Gonzalez-Rosario, Lisett transaction or occurrence)? NO
Name of Defendant’s Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): Unknown
Are sexual abuse claims alleged by: Lisett Gonzalez-Rosario? NO
Are sexual abuse claims alleged by: Lidiana Gonzalez-Rosario?
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
Medical Debt Claim? 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)
PAS-L-000241-24 01/23/2024
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TransID:
ID:LCV2024189349
LCV2024189349
01/23/2024 /s/ DANIEL SANTIAGO
Dated Signed
Preview
PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 1 of 5 Trans ID: LCV2024189349 Law Office of Daniel Santiago, LLC Daniel Santiago, Esq. – 021212006 Allison R. Ramelson-Kert, Esq. - 411282022 695 U.S. 46 Suite 301C Fairfield, New Jersey 07004 P (973) 777-9700 F (973) 546-3749 Attorneys for Plaintiffs LISETT GONZALEZ-ROSARIO and Superior Court of New Jersey LIDIANA GONZALEZ-ROSARIO, Law Division: Passaic County Plaintiff, Docket: PAS-L- vs CIVIL ACTION NYESHA GREEN, NEW JERSEY TRANSIT CORPORATION, JOHN DOES 1-10 (Being a fictitious name), and COMPLAINT, DESIGNATION OF TRIAL ABC CORPORATION (being a COUNSEL, AND JURY DEMAND fictitious entity). Defendants Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-ROSARIO, by the way of Complaint against the above Defendants, says: FIRST COUNT 1. On or about March 9, 2022, Plaintiff, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-ROSARIO, at approximately 8:13 A.M. were travelling southbound on Main Avenue. Plaintiffs were stopped at the intersection of Main Avenue and Monroe Street at a red traffic light signal, when a vehicle negligently failed to stop at the red light and collided into Plaintiffs’ vehicle. PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 2 of 5 Trans ID: LCV2024189349 2. The vehicle which struck Plaintiff’s car, was owned by New Jersey Transit Corporations, and operated by Defendant Nyesha Green. 3. Upon information and belief, at all times relevant to this complaint, Nyesha Green was acting as a servant, agent, or employee of NJ Transit. 4. As a result of Defendants’ negligence, Plaintiff was severely and permanently insured, suffered great pain and mental anguish, required and in the future, will require medical care and attention, was and in the future, will be compelled to expend large sums of money for said medical care and attention and was and in the future, will be prevented from engaging in her normal pursuits and occupations. WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ-ROSARIO, demands judgment against the Defendant for damages, together with interest and cost of suit. SECOND COUNT 1. Plaintiff repeats and realleges each allegation made forth in the First Count as though fully set forth at length herein. 2. At the same time and place, Defendants, John Does 1-10, were the operators and owners of the vehicles which were owned, operated, and maintained in a careless, reckless, and negligent manner. 3. As a result of Defendants’ negligence, Plaintiff was severely and permanently insured, suffered great pain and mental anguish, required and in the future, will require medical care and attention, was and in the future, will be compelled to expend large PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 3 of 5 Trans ID: LCV2024189349 sums of money for said medical care and attention and was and in the future, will be prevented from engaging in her normal pursuits and occupations. WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ- ROSARIO, demands judgment against the defendants for damages, together with interest and cost of suit. THIRD COUNT 1. Plaintiff repeats and realleges each allegation made forth in the First Count as though fully set forth at length herein. 2. At the same time and place, Defendants, ABC Corporation, were the operators and owners of the vehicles which were owned, operated, and maintained in a careless, reckless, and negligent manner. 3. As a result of Defendants’ negligence, Plaintiff was severely and permanently insured, suffered great pain and mental anguish, required and in the future, will require medical care and attention, was and in the future, will be compelled to expend large sums of money for said medical care and attention and was and in the future, will be prevented from engaging in her normal pursuits and occupations. WHEREFORE, Plaintiffs, LISETT GONZALEZ-ROSARIO and LIDIANA GONZALEZ- ROSARIO, demands judgment against the defendants for damages, together with interest and cost of suit. PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 4 of 5 Trans ID: LCV2024189349 JURY DEMAND PLEASE TAKE NOTICE that Plaintiff demands a trial of the issues by jury. DESIGNATION OF TRIAL COUNSEL Pursuant to the Rules of Court 4:25-4, the Court is hereby advised that Daniel Santiago, Esq. is hereby designated as trial counsel in the within matter. DEMAND FOR DISCOVERY Plaintiff demands that Defendant answer Form C and C (1) Interrogatories located in the New Jersey Court Rules, Appendix II, pursuant to R. 4:17 in a manner and within time prescribed by the Rules of the Court. DEMAND FOR DOCUMENT PRODUCTION Plaintiff demands that Defendants produce any document or paper referred to in plaintiff’s Complaint, pursuant to R.4:18-2 in a manner and within the time frame prescribed by the Rules of Court. NOTICE PURSUANT TO RULE 1:5-1 PLEASE TAKE NOTICE that the undersigned attorneys do hereby demand, pursuant to the above cited Rules of Court, that each party herein serving pleadings and interrogatories and serving answers thereto, serve copies of all such pleadings and answered interrogatories and all supplements, papers and other material referred to therein, received PAS-L-000241-24 01/23/2024 8:27:58 AM Pg 5 of 5 Trans ID: LCV2024189349 from any party, upon the undersigned attorneys, and TAKE NOTICE that this is a CONTINUING demand. CERTIFICATION PURSUANT TO RULE 4:5-1 The undersigned is presently unaware of any Court or arbitration proceeding which is presently pending and which relates to the matter in controversy, and none is contemplated by the undersigned. The undersigned is presently unaware of any other party who should be joined in this action. I hereby 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. Dated: January 23, 2024 By:__________________________ Daniel Santiago, Esq., CERTIFICATION OF FILING AND SERVICE It is hereby certified that a copy of the Complaint has been filed with the Clerk of in the New Jersey Superior Court in Passaic County, and that copies have been served upon all parties within the time provided by the Rules of Court. Dated: January 23, 2024 By:__________________________ Daniel Santiago, Esq. PAS-L-000241-24 01/23/2024 PAS-L-000241-24 01/23/20248:27:58 8:27:58AM AM Pg 1 of 2 Trans TransID: ID:LCV2024189349 LCV2024189349 Civil Case Information Statement Case Details: PASSAIC | Civil Part Docket# L-000241-24 Case Caption: GONZALEZ-ROSARIO LISETT VS GREEN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- NYESHA VERBAL THRESHOLD) Case Initiation Date: 01/23/2024 Document Type: Complaint with Jury Demand Attorney Name: DANIEL SANTIAGO Jury Demand: YES - 6 JURORS Firm Name: DANIEL SANTIAGO Is this a professional malpractice case? NO Address: 695 US-46 STE 301 C Related cases pending: NO FAIRFIELD NJ 07004 If yes, list docket numbers: Phone: 9737779700 Do you anticipate adding any parties (arising out of same Name of Party: PLAINTIFF : Gonzalez-Rosario, Lisett transaction or occurrence)? NO Name of Defendant’s Primary Insurance Company Does this case involve claims related to COVID-19? NO (if known): Unknown Are sexual abuse claims alleged by: Lisett Gonzalez-Rosario? NO Are sexual abuse claims alleged by: Lidiana Gonzalez-Rosario? 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 Medical Debt Claim? 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) PAS-L-000241-24 01/23/2024 PAS-L-000241-24 01/23/20248:27:58 8:27:58AM AM Pg 2 of 2 Trans TransID: ID:LCV2024189349 LCV2024189349 01/23/2024 /s/ DANIEL SANTIAGO Dated Signed