Preview
BER-L-001188-24 02/23/2024 Pglof1 Trans ID: LCV2024489605
‘
Form C
Plaintiff O Check if new address/phone number
Name Great Group Home Improvement llc Superior Court of New Jersey
Address Law Division, Special Civil Part
Bergen County
Email Address Docket Number SC-1195-23
Telephone Number ext.
vs.
Defendant O Check if new address/phone number
Civil Action
Name Jenna Winston
Address 71 Barrington Road Order
Ridgewood, NJ 07450
Email Address jenna.winstonparsle mail.com
Telephone Number (610) 564-3940" ext.
i
This matter being opened to the court by, Jenna Winston , (your name)
the D Plaintiff / Defendant in the case by way of motion seeking an order to:
Permit Discdvery O1 Amend Judgment
O Vacate Dismissal/Reinstate Complaint O Enter Judgment Out of Time
O Amend Complaint O Vacate Default/Vacate Default Judgment
O Amend Answer HM Other (Specify)
Transfer to law
and the court having considered the motion, pleadings on file and/or argument of the moving
party and for good cause appearing;
(Do not write below this line, for court use only)
On this day of > 20__, it is ORDERED that:
It is FURTHER ORDERED that a copy of this Order be served by the moving party upon all
other parties or their attorneys, if any, within days of the date listed above.
This motion was:
O Opposed 01 Unopposed
Revised 08/03/2022, CN 10543 page
11 of 11
BER-L-001188-24 02/23/2024 Pglof6 Trans ID: LCV2024489605
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Form A
CA
y MC
Plaintiff or Filing Attorney Information: < ge >
Name Jenna Winston 2 she
NJ Attorney ID Number —
ae _ ok
Address 71 Barrington Road
Ridgewood, N.J. 07450
Email Address jenna. winstonparsley@gmail.com
Telephone Number (610) 564-3940 ext.
Superior Court of New Jersey
Law Division
Bergen County
Great Group rome Improvement LLC” ‘
Docket Number DL — B-23
Plaintiff,
Vv.
Civil Action B a
Jenna Winston
Defendant(s). Notice ofMotion ©r=
ae “or
= Or
To:
ma
awo
WES
m
TAKE NOTICE that the undersigned will apply to the above named Court lo ecbat a
10 Main Street, Hackensack, NJ 07601 m
i
onJanuary 12, 2024 at 9:00 a.m. for an Order to (describe telief requested): ¢>
Transfer the above captioned matter from the Special Civil Part- Small Claims Section (Dodket
No. SC 1195-23) to the Law Division because the damages sought b' Defend t insher ropesed
counterclaim exceed $20,000. {a
ot Shr
Permit the Defendant to file the proposed counterclaim attached to h
whe
the instant motion
oo
I will rely on-the attached certification which contains the grounds for the relief sought».
lw
Pursuant to R. 1:6-2(d), the undersigned: (check one)
1 Waives oral argument and consents to disposition on the papers. RECENVED/FILED
&) Requests oral argument if this matter is contested 02 2 +
1 Requests oral argument for the following a a, ac SUPERIGR COURT or NEW ERBEY
OUNTY OF Bt
CBNANES DRS
Date Filed oi ———
Paymont # AX fa
ch cK
A proposed form of Order is attached. Amount _—_— WY
Revised 08/15/2022, CN 10555 PayorStee 024
page 9 of 14
HEFH
Y. JERSEY
SUPER
AN Ge bi ON
OER eae 02/23/2024 Pg2of6 Trans ID: LCV2024489605
=
Form A
Court Dates
No pre-trial conference, arbitration pro
ceeding, calendar call or trial date has been set except as
follows: (If any dates have been schedu
led, no te them here; of therwise, state “none”
Trial in the Small Claims Section, Docket ‘No. SC 1195-23,
is scheduled for January 16, 2024.
Discovery End Date
Qo . Discovery in this matter is'schéduled to be completed on
A discovery end date has not been assigned to thismatter.
Certification Regarding Attempts to Resolve
(Required for discovery and calendar motions — check one)
I certify that I have personally discussed this matter with the attomey for the opposing
party, or the opposing party if appearing pro se, in order to resolve the issues raised by this
motion. This effort was not successful.
I certify that I have made a good faith effort to personally discuss this matter with
the
attomey for the opposing party, or with the party if appearing pro se, in order to resolve
the
issues raised by this motion. The effort I made included the following action: (specify
attempts to confer):
O1 Icertify that I have advised the attorney for the oppo
sing party, or the party if appearing
pro se, by letter that if I will-make this motion if she/he c ontinues
to fail to comply with
my discovery request,
I certify that the foregoing statements made b y me are
true. I am aware that if any of the
foregoing statem ents are willfully false, I am Subject to punishment.
1/1/2024 ( 7
“3 ay
Date Signature N
Jenna Winston
Print Name
BER-L-001188-24 02/23/2024 Pg3o0f6 Trans ID: LCV2024489605
ali =
Form A
If this is the first paper you are filing in this case, you must sign the following certification.
I certify that confidential personal identifiers have been redacted from documents now
Ee
submitted to the court and will be redacted from all documents submitted in the future in
accordance with Rule 1:38-77(b).
1/1/2024
Date Signature,
Jenna inston
Print Name
Revised 08/15/2022, CN 10555
page Il of 14
BER-L-001188-24 02/23/2024 Pg4of6 Trans ID: LCV2024489605
,
Se =
Form B
Plaintiff or Filing Attorney Information
Name lan Linker, Esquire
NJ Attomey ID Number
Address _71 Barrington Road
Ridgewood,
NJ.07450
Email Address ianlinker2012@gmail.com
Telephone Number (610) 564-3940 _ ext.
Superior Court of New Jersey
Law Division
Great Group Home Improvement LLC Soirenaier S re 5 a >
Plaintiff,
Vv.
Civil Action
Jenna Winston
Certification in Support of Motion
Defendant(s).
I, Jenna Winston , am the (check one) O plaintiff /&d defendant in the
above-captioned matter. I make this certification in support of my motion to: (state what you
want the court to do)
Transfer the above captioned matter from the Special Civi
No. SC 1195-23) to the Law Division.
This motion should be granted because: (State the basis for your motion and why is should be
granted. Use extra paper if necessary.)
The damages sought by Defendant in her proposed counterclaim exceed $20,000.
Defendant has tached heret
I certify that the above statements made by me are true and that if any of the statements are
“CA
willfully false, I am subject to punishments
12/29/2023
Date Sigyatute
Jenna Winston
Print Name
Revised 08/15/2022, CN 10555 page12 of 14
BER-1-001188-24 02/23/2024 Pg5of6 Trans ID: LCV2024489605
FormB
Certification of Service
I certify that on 12/29/2023 I sent a copy of the Notice of Motion, Certification, and
proposed form of Order to the following parties by: (check which mailing method you chose. If
you sent it by both regular and certified mail, return receipt requested, check both)
& regular mail & certified mail, return receipt requested
List each party to the lawsuit; use the attomey’s name and address if the party is represented by
counsel,
Name Great Group Home Improvement LLC Name
Address _231 Columbus Place Address
Cliffside Park, NJ 07010 =
Attomey for Attomey for
Date 1/1/2024
[=
fF
Signa’
Jenna Winston
Print Name
Revised 08/15/2022, CN 10555 page 13 of 14
BER-L-001188-24 02/23/2024 Pg6of6 Trans ID: LCV2024489605
Form C
Plaintiff or Filing Attorney Information:
Name lan Linker, Esq,
NJ Attorney ID Number 181322019
Address 71 Barrington Road
Ridgewood,
NUOZ450
Email Address djanlinker2012@gmail.com
Telephone Number (646)
(646) 529-759
529-75933 ext.
ext.
Superior Court of New Jersey
Law Division
Bergen County
Great.Group Home Improvement LLC. DocketNumber S(C- 1196-25
Plaintiff,
Vv.
Civil Action
Jenna Winston
Order
Defendant(s),
This matter having been brought before the Court on Motion of O plaintiff /K] defendant for an
Order (describe relief requested):
Transferring the above captioned matter to the Law Division from the Special Civil Part -
Small Claims Section, (Docket No. SC 1195-23), because the damages sought by Defendant's
and granting Defendant's request to file the proposed
counterclaim attached to her certification in support of the instant motion.
and the Court having considered the matter and for good cause appearing,
On this day of 20. )__, itis ORDERED as follows:
The Court grants Defendant's motion to transfer to this Court from the Special Civil Part -
Small Claims Section, Docket No. SC 1195-23, because the damages sought by Defendant:
proposed counterclaim exceed $20,000.
The Court further grants Defendant's request to file the proposed counterlclaim attached t
her Certification in support of the instant motion.
The instant matter is no longer pending in the Small Claims Section. A new docket number
shall be assigned.
D Opposed 0 Unopposed ee
J.S.C
Revised 08/15/2022, CN 10555
page 14 of 14
BE Ao ea 02/23/2024 Pglof10 Trans ID: LCV2024489605
J enna Winston
71 Barrington Road
Ridgewood, NJ 07450
jenna.winstonparsley@gmail.com
(610) 564-3940
Superior Court of New Jersey
Law Division
Bergen County
Docket No.
Great Group Home Improvement LLC,
Plaintiff, Civil Action
Vv. Counterclaim
Jenna Winston,
Defendant
Pursuant to R. 4:7, Defendant Jenna Winston, a/k/a Jenna Linker (“Linker”), files this
counterclaim against Plaintiff Great Group Home Improvement LLC (the “Contractor”) and
alleges as follows:
PRELIMINARY STATEMENT
1 After preparing and signing a contract, omitting information mandated by and in
violation of New Jersey law, in which the Plaintiff contractor agreed to undertake certain home
improvements in the Defendant’s home, he performed shoddy work, consequently wasting
thousands of dollars in materials provided by the Defendant, flooded the Defendant’s basement
with concrete destroying the Defendant’s washing machine and basement floor, spilled concrete
and debris on the Defendant’s outside walkway, and quit the job after demolishing the
Defendant’s only bathroom on the main level, leaving her and her family of four children without
a bathroom on that level. He quit the job before completing the agreed upon work, apparently
because he did not like getting feedback from the Defendant or her husband about the quality of
his work. He demanded partial payment after quitting, even though the contract said nothing
ot eae 02/23/2024 Pg2of10 Trans ID: LCV2024489605
'
about partial payment or any payment before the work was complete. He agreed to replace the
Defendant’s washing machine, which he acknowledged was broken, and then retracted the offer
when the Defendant refused to make a partial payment. The Plaintiff breached the contract, was
negligent, which damaged the Defendant’s property, and repeatedly violated New Jersey’s
Consumer Fraud Act. Plaintiff should pay treble damages and the Defendants costs.
FACTUAL ALLEGATIONS
2, On November 13, 2023, the parties signed a contract, in which plaintiff Great Group
Home Improvement LLC (the “Contractor”) agreed to undertake certain work set forth therein
and the homeowner defendant, Jenna Winston, a/k/a Jenna Linker (“Linker”), agreed to pay the
Contractor $9,500 to complete the work (“Contract”). To keep costs down, Linker agreed to
purchase the materials separately. The Contract is attached hereto as Exhibit “A”.
3 The scope of work included removing the molding trim through most of the main level of
Linker’s home, including the main level bathroom, and replacing it with a PVC trim
(Unbeknownst to Linker, the trim the Contractor’s representative recommended is typically used
for exterior projects), replacing four interior doors on the main level, removing and replacing
floor tile in the main level bathroom (the only bathroom on the main level), and removing and
replacing the toilet and vanity in the main level bathroom, and cleaning up debris.
4 The Contractor took measurements and instructed Linker how much molding to purchase
and the dimensions of the four doors she needed to buy.
5 The Contract did not state that Linker owed the Contractor a deposit or a partial payment
at various points during the course of the project. The Contract also did not give the Contractor
the right to cancel the Contract or quit the job before he completed the work and demand a
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partial payment for labor. In fact, the Contract said nothing about an hourly rate for labor. It
merely said the Contractor would provide labor.
6 The Contract also did not provide the legal name and address of the Contractor’s
representative, who signed the Contract on the Contractor’s behalf, who was Linker’s primary
point of contact, nor did it provide a start and end date or include a copy of the certificate of the
Contractor’s general liability insurance.
7 The Contractor began the work on November 14, 2023. He typically had one worker with
him. Occasionally he brought a second. He removed the existing floor tile, the vanity, and the
toilet, and removed the existing molding in the bathroom and throughout the main level of
Linker’s home.
8 During this early phase of the project, significant amounts of debris from the bathroom
fell through the floor into Linker’s basement laundry room. After Linker’s husband notified the
Contractor about the debris, he cleaned up the basement and covered the floor and the laundry
machines with plastic.
9 The Contractor damaged walls while removing the molding in the living room, causing
significant damage to one and minor damage to a second. The Contractor’s workers cut molding
in Linker’s yard, spraying white PVC dust in the flower beds and on the walkways while they
cut. The Contractor hung molding. The work was substandard throughout.
10. One of the Contractor’s workers cut and hung the molding around the entry way between
Linker’s den and living room apparently without considering how she wanted the molding cut.
The Contractor agreed and took down the molding. In multiple locations, the molding work
looked like the workers had simply cut the right length and slapped it up onto the wall, including
on the entry way between the kitchen and the dining room where the trim was cut wider on one
BER--001188-24 02/23/2024 Pg4of10 Trans ID: LCV2024489605
side than the other, apparently to hide the holes in the wall that the Contractor had caused when
he pulled off the old molding on that side. Another example of the shoddy workmanship was on
the bathroom doorway. There, they cut the molding in a way that caused the doorway to be an
inch and a half to two inches narrower than it had been before, making entry a challenge. Linker
and her husband showed the Contractor these and other locations where the molding had been
hung sloppily or without considering how Linker wanted the molding cut and hung. On each
occasion, the Contractor agreed and said he would remove the molding and cut and hang it again.
qi, The Contractor and his workers began to lay the bathroom floor tile. Per the Contractor’s
advice, Linker purchased six boxes of tile to complete the six foot by nine foot rectangular
bathroom. The Contractor never said anything about the type of tile Linker purchased at any
time after she purchased it.
12. By November 20, 2023, although the Contractor had not completed the tile work in the
bathroom, it was clear that this work was also substandard. Placing a level on the tiled floor
showed how unlevel the work was. In fact, in at least one spot, the tile the Contractor put down
was so bad, there was a visible space between the level and the tile. Further, there were
noticeable uneven ridges in several spots on the newly tiled floor. The Contractor agreed the
work was unacceptable and removed the tile. Linker purchased additional tile for $713 to
replace the tile wasted by the Contractor’s poor workmanship.
13. Two days later, without telling Linker or her husband what the Contractor intended to do
or that he intended to use self-leveling concrete in the bathroom before his second attempt to lay
the floor tile, he poured concrete onto the bathroom floor after mixing it and spilling it on the
front walkway. Because Linker did not know what the Contractor had planned, she had briefly
pulled back the plastic sheet that the Contractor had put down in the basement, so her family
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sould use ‘is laundry machines. Knowing how much debris had fallen through the floor into the
basement when he demolished the bathroom, the Contractor should have known that the concrete
would flood the basement. The liquid concrete landed on and ran into Linker’s one year old LG
brand washing machine and in multiple spots on the basement floor.
14. Linker’s husband attempted to salvage the washing machine. When he told the
Contractor about the concrete flood, the Contractor, who apparently realized that running a
washing machine damaged by a significant quantity of concrete was unwise, asked Linker’s
husband not to use the machine. The Contractor accepted responsibility for the machine and
initially said he would replace it. Linker did not use the machine until she and her husband
tested it on November 27. During the test, water began leaking immediately from the bottom of
the machine. Linker’s husband, who had recorded the test, stayed to watch, turned off the
machine and cleaned up the water.
15. Linker had been sending out the family’s laundry since the Contractor broke their
washing machine. Early on November 27, Linker’s husband texted the Contractor’s
representative, Mike: “Good morning, I sent you the washing machine model number. When is it
supposed to be delivered?”
16. Mike responded:
“Good morning
It is coming on December 15”
Ws Linker’s husband texted back:
“Okay. While I certainly appreciate that you ordered it already, it costs us more than $90 a week
to send out our laundry.” (There are six people living in Linker’s home.)
BER es 02/23/2024 Pg6of10 Trans ID: LCV2024489605
18, Bven though he had previously said not to use the machine and had not sent over
someone to determine whether the machine was broken, Mike said:
Use yours until is delivered
It is not broken
We need a payment today for $5500
Please thank you. I appreciate it.
19. Linker’s husband responded:
“Okay. What kind of caulk should we get?”
20. Mike replied:
“White caulking for molding
You can ask them and they will show it”
21, Linker’s husband then said:
“We’re buying it online. What kind of caulking?”
22. Mike did not respond to this question.
23. Instead, with a demolished bathroom, poorly hung, unpainted, and unsealed molding, and
sections of the main level bare and without any molding, the Contractor’s representative Mike
notified Linker’s husband after the above exchange also by text message on November 27, 2023,
that he was “discontinuing” the work, i.e., quitting the job, because according to him, he was
“losing a lot of money.” The Contractor was apparently concerned that Linker would continue
objecting to his substandard work.
24. He stated:
As of today you owe us $5500 + []
$450 that I “payed for your materials and the work that was done
-$1800 your washing machine
-$700 for your tiles
You owe us $4450
Pee ee 02/23/2024 Pg7of10 Trans ID: LCV2024489605
25, A lengthy exchange where Mike, on behalf of the Contractor, attempted to persuade
Linker’s husband to pay him $5,000, or $3,000 if he cleaned up the mess he left, even refusing to
replace the washing machine if Linker did not agree to pay him.
26. Linker found another contractor to address the shoddy work, order new materials, and
complete the job properly. The new contractor agreed to complete the job for $9,600, or $100
more than the Contractor requested to complete the job. The new contractor requested 50
percent of the payment half-way through the job.
CAUSES OF ACTION
FIRST CAUSE OF ACTION — BREACH OF CONTRACT
27. Linker incorporates paragraphs 1-26 as if restated fully herein.
28. Linker and the Contractor entered into a contract on November 13, 2023, in which the
Contractor agreed to undertake a specific list of home repairs and Linker agreed to pay the
Contractor $9,500 in exchange for this work.
29. The contract between Linker and the Contractor did not say that Linker would owe a
partial payment or any payment prior to completion of the work.
30. The Contractor quit the job before he completed the work and demanded partial payment
in breach of contract.
31s As a result of the Contractor’s breach, Linker has been damaged.
32. Linker paid for the materials under the contract and lost $1,804.45 for the wasted and
improper molding, $713.06 for the tile the Contractor wasted, and an additional $5,000 to fix the
Contractor’s substandard work.
SECOND CAUSE OF ACTION — NEGLIGENCE
33. Linker incorporates paragraphs 1-32 as if restated fully herein.
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34, It was foreseeable that using Linker’s front paver walkway as a staging area to mix
concrete and to cut PVC trim could cause damage to the walkway and the adjacent flower beds.
Thus, the Contractor owed Linker a duty of care.
35. It was also foreseeable that pouring liquid concrete onto the bathroom floor could cause
damage to the basement, because when the Contractor demolished the bathroom significant
quantities of concrete chunks and debris fell into the basement. Thus, the Contractor owed
Linker a duty of care.
36. The Contractor spilled concrete on the walkway and the white PVC dust stained and
damaged Linker’s walkway.
37. Because it was reasonably foreseeable that mixing concrete and using a power saw on
white PVC on a paver stone walkway would cause damage thereto, the Contractor’s negligence
was the proximate cause of the damage to Linker’s walkway.
38. The Contractor poured concrete onto the bathroom and it spilled into the basement
several days after the Contractor had spread a plastic cover over the washing machine. However,
he did not notify Linker that he intended to pour liquid onto the bathroom floor or take any steps
to ensure that the plastic cover was still in place protecting the washing machine. The
Contractor’s negligence caused damage to the washing machine and Linker’s laundry room floor.
39. Because it was reasonably foreseeable that pouring concrete onto a floor that had
previously dropped significant quantities of debris into the basement would cause damage
thereto and to the washing machine, the Contractor’s negligence and failure to communicate with
Linker about his intention to pour concrete into such a room, was the proximate cause of the
damage to Linker’s washing machine and her laundry room floor.
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40. The senching machine cost $1,999 to replace plus $132.43 in tax, or $2,131.43. The
replacement machine is comparable to the machine the Contractor damaged.
41. While Linker was without a washing machine, she was damaged in the amount of
$309.20 to send out her and her family’s laundry.
THIRD CAUSE OF ACTION — CONSUMER FRAUD ACT
42. Linker incorporates paragraphs 1-41 as if restated fully herein.
43. The Contractor violated the New Jersey Consumer Fraud Act, and New Jersey’s
Administrative Code incorporated therein. Linker suffered a loss therefrom. And the
Contractor’s conduct caused said losses. Accordingly, the Contractor should pay Linker treble
damages plus costs.
44. The Contractor violated the CFA as follows:
He performed substandard work as described above;
He demanded partial payment before completing the work;
He quit the job before completing the work;
He knowingly failed to disclose that he expected a partial payment before completing
the work, which rendered untrue, or at a minimum misleading, the contract, which
contained no provision for a partial payment (NJAC § 13:45A-16.2(9)(ii));
The contract failed to disclose, and the Contractor failed to mention that he required a
partial payment before completion (NJ Rev Stat § 56:8-151(3) (2022); NJAC §
13:45A-16.2(6)(vi));
The contract failed to provide the legal name and business address of the Contractor’s
representative, who negotiated and signed the contract (NJAC § 13:45A-16.2(12)(i));
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2. The contract failed to disclose the dates on which the work was to begin and end by
the Contractor (NJAC § 13:45A-16.2(12)(iv));
The contract failed to include a copy of the certificate of commercial general liability
insurance (NJAC § 13:45A-16));
The contract failed to clearly disclose the total price to be paid by Linker, including
partial payments for incomplete work and hourly labor charges (NJAC § 13:45A-
16.2(12)(iii)).
45. The Contractor’s violations caused the losses Linker sustained as alleged herein.
WHEREFORE, Defendant Jenna Winston, a/k/a Jenna Linker respectfully requests a
judgment against Plaintiff Great Group Home Improvement LLC for treble damages, or
$28,946.82, plus costs.
Jenna Wi on,
Dated: January 1, 2024
10
BERL-001188-24 02/23/2024 Pglof8 Trans ID: LCV2024489605
EXHIBIT
BER-L-001188-24 02/23/2024 Pg2of8 Trans ID: LCV2024489605
INVOIKC I
t
Bill To
‘is Jenna Winston
“GREAT GROUP 71 Barrington Rd
Nowe tuPRoveMenT ite
Ridgewood, Nj 07450
(610) 564-3940
Great Group Home Improvement LLC Payment terms Due upon receipt
Invoice # 16671
231 Columbus Pl
Cliffside Park, Nj 07010 Date 11/13/2023
Phone: (973) 262-2641
Email: greatgrouphomeimprovement@gmail.com
Web: greatgrouphomeimprovementllc.com
Description
Exterior & Interior
* Replace 7 baseboard covers x 6’ each L
+ Replace 4 baseboard for heating 63”L
+ Replace 60’ L x 8"W base trim
+ Replace 1x8”x8'x 23’
+ Replace 28’ of 1x6x8’
+ Replace 1 piece x1x2x8’
2, Replace Same measures another door way as above .
* Replace 1 door 28x80”
* Replace 2 door 32x80”
+ Replace 1x5”x 20' of base molding
* Replace 1 vanity in the bathroom
* Replace 1 toilet in the bathroom
* Replace Bathroom tiles 6'x9' in the bathroom
* Clean up Debris
+ All material provided by the client
+ Labor is provided by our company
Subtotal $9,500.00
Total $9,500.00
Page 1 of6
BER-L-001188-24 02/23/2024 Pg3o0f8 Trans ID: LCV2024489605
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BER-L-001188-24 02/23/2024 Pg7of8 Trans ID: LCV2024489605
Pua, Lit
oe ees es
‘signed on: 1113/2023 Signed on: 11/13/2023
Great Group Home Improvement LLC Jenna Winston
Page 6 of6
BER-L-001188-24 02/23/2024 Pg 8of8 Trans ID: LCV2024489605
‘
Form C
Plaintiff O Check if new address/phone number
Name Great Group Home Improvement llc Superior Court of New Jersey
Address Law Division, Special Civil Part
Bergen County
Email Address Docket Number SC-1195-23
Telephone Number ext.
vs.
Defendant O Check if new address/phone number
Civil Action
Name Jenna Winston
Address 71 Barrington Road Order
Ridgewood, NJ 07450
Email Address jenna.winstonparsle mail.com
Telephone Number (610) 564-3940" ext.
i
This matter being opened to the court by, Jenna Winston , (your name)
the D Plaintiff / Defendant in the case by way of motion seeking an order to:
Permit Discdvery O1 Amend Judgment
O Vacate Dismissal/Reinstate Complaint O Enter Judgment Out of Time
O Amend Complaint O Vacate Default/Vacate Default Judgment
O Amend Answer HM Other (Specify)
Transfer to law
and the court having considered the motion, pleadings on file and/or argument of the moving
party and for good cause appearing;
(Do not write below this line, for court use only)
On this day of > 20__, it is ORDERED that:
It is FURTHER ORDERED that a copy of this Order be served by the moving party upon all
other parties or their attorneys, if any, within days of the date listed above.
This motion was:
O Opposed 01 Unopposed
Revised 08/03/2022, CN 10543 page
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BER-L-001188-24 02/23/2024 Pglof1 Trans ID: LCV2024489605 ‘ Form C Plaintiff O Check if new address/phone number Name Great Group Home Improvement llc Superior Court of New Jersey Address Law Division, Special Civil Part Bergen County Email Address Docket Number SC-1195-23 Telephone Number ext. vs. Defendant O Check if new address/phone number Civil Action Name Jenna Winston Address 71 Barrington Road Order Ridgewood, NJ 07450 Email Address jenna.winstonparsle mail.com Telephone Number (610) 564-3940" ext. i This matter being opened to the court by, Jenna Winston , (your name) the D Plaintiff / Defendant in the case by way of motion seeking an order to: Permit Discdvery O1 Amend Judgment O Vacate Dismissal/Reinstate Complaint O Enter Judgment Out of Time O Amend Complaint O Vacate Default/Vacate Default Judgment O Amend Answer HM Other (Specify) Transfer to law and the court having considered the motion, pleadings on file and/or argument of the moving party and for good cause appearing; (Do not write below this line, for court use only) On this day of > 20__, it is ORDERED that: It is FURTHER ORDERED that a copy of this Order be served by the moving party upon all other parties or their attorneys, if any, within days of the date listed above. This motion was: O Opposed 01 Unopposed Revised 08/03/2022, CN 10543 page 11 of 11 BER-L-001188-24 02/23/2024 Pglof6 Trans ID: LCV2024489605 " ar ips aT 1 0...— Kah HH Form A CA y MC Plaintiff or Filing Attorney Information: < ge > Name Jenna Winston 2 she NJ Attorney ID Number — ae _ ok Address 71 Barrington Road Ridgewood, N.J. 07450 Email Address jenna. winstonparsley@gmail.com Telephone Number (610) 564-3940 ext. Superior Court of New Jersey Law Division Bergen County Great Group rome Improvement LLC” ‘ Docket Number DL — B-23 Plaintiff, Vv. Civil Action B a Jenna Winston Defendant(s). Notice ofMotion ©r= ae “or = Or To: ma awo WES m TAKE NOTICE that the undersigned will apply to the above named Court lo ecbat a 10 Main Street, Hackensack, NJ 07601 m i onJanuary 12, 2024 at 9:00 a.m. for an Order to (describe telief requested): ¢> Transfer the above captioned matter from the Special Civil Part- Small Claims Section (Dodket No. SC 1195-23) to the Law Division because the damages sought b' Defend t insher ropesed counterclaim exceed $20,000. {a ot Shr Permit the Defendant to file the proposed counterclaim attached to h whe the instant motion oo I will rely on-the attached certification which contains the grounds for the relief sought». lw Pursuant to R. 1:6-2(d), the undersigned: (check one) 1 Waives oral argument and consents to disposition on the papers. RECENVED/FILED &) Requests oral argument if this matter is contested 02 2 + 1 Requests oral argument for the following a a, ac SUPERIGR COURT or NEW ERBEY OUNTY OF Bt CBNANES DRS Date Filed oi ——— Paymont # AX fa ch cK A proposed form of Order is attached. Amount _—_— WY Revised 08/15/2022, CN 10555 PayorStee 024 page 9 of 14 HEFH Y. JERSEY SUPER AN Ge bi ON OER eae 02/23/2024 Pg2of6 Trans ID: LCV2024489605 = Form A Court Dates No pre-trial conference, arbitration pro ceeding, calendar call or trial date has been set except as follows: (If any dates have been schedu led, no te them here; of therwise, state “none” Trial in the Small Claims Section, Docket ‘No. SC 1195-23, is scheduled for January 16, 2024. Discovery End Date Qo . Discovery in this matter is'schéduled to be completed on A discovery end date has not been assigned to thismatter. Certification Regarding Attempts to Resolve (Required for discovery and calendar motions — check one) I certify that I have personally discussed this matter with the attomey for the opposing party, or the opposing party if appearing pro se, in order to resolve the issues raised by this motion. This effort was not successful. I certify that I have made a good faith effort to personally discuss this matter with the attomey for the opposing party, or with the party if appearing pro se, in order to resolve the issues raised by this motion. The effort I made included the following action: (specify attempts to confer): O1 Icertify that I have advised the attorney for the oppo sing party, or the party if appearing pro se, by letter that if I will-make this motion if she/he c ontinues to fail to comply with my discovery request, I certify that the foregoing statements made b y me are true. I am aware that if any of the foregoing statem ents are willfully false, I am Subject to punishment. 1/1/2024 ( 7 “3 ay Date Signature N Jenna Winston Print Name BER-L-001188-24 02/23/2024 Pg3o0f6 Trans ID: LCV2024489605 ali = Form A If this is the first paper you are filing in this case, you must sign the following certification. I certify that confidential personal identifiers have been redacted from documents now Ee submitted to the court and will be redacted from all documents submitted in the future in accordance with Rule 1:38-77(b). 1/1/2024 Date Signature, Jenna inston Print Name Revised 08/15/2022, CN 10555 page Il of 14 BER-L-001188-24 02/23/2024 Pg4of6 Trans ID: LCV2024489605 , Se = Form B Plaintiff or Filing Attorney Information Name lan Linker, Esquire NJ Attomey ID Number Address _71 Barrington Road Ridgewood, NJ.07450 Email Address ianlinker2012@gmail.com Telephone Number (610) 564-3940 _ ext. Superior Court of New Jersey Law Division Great Group Home Improvement LLC Soirenaier S re 5 a > Plaintiff, Vv. Civil Action Jenna Winston Certification in Support of Motion Defendant(s). I, Jenna Winston , am the (check one) O plaintiff /&d defendant in the above-captioned matter. I make this certification in support of my motion to: (state what you want the court to do) Transfer the above captioned matter from the Special Civi No. SC 1195-23) to the Law Division. This motion should be granted because: (State the basis for your motion and why is should be granted. Use extra paper if necessary.) The damages sought by Defendant in her proposed counterclaim exceed $20,000. Defendant has tached heret I certify that the above statements made by me are true and that if any of the statements are “CA willfully false, I am subject to punishments 12/29/2023 Date Sigyatute Jenna Winston Print Name Revised 08/15/2022, CN 10555 page12 of 14 BER-1-001188-24 02/23/2024 Pg5of6 Trans ID: LCV2024489605 FormB Certification of Service I certify that on 12/29/2023 I sent a copy of the Notice of Motion, Certification, and proposed form of Order to the following parties by: (check which mailing method you chose. If you sent it by both regular and certified mail, return receipt requested, check both) & regular mail & certified mail, return receipt requested List each party to the lawsuit; use the attomey’s name and address if the party is represented by counsel, Name Great Group Home Improvement LLC Name Address _231 Columbus Place Address Cliffside Park, NJ 07010 = Attomey for Attomey for Date 1/1/2024 [= fF Signa’ Jenna Winston Print Name Revised 08/15/2022, CN 10555 page 13 of 14 BER-L-001188-24 02/23/2024 Pg6of6 Trans ID: LCV2024489605 Form C Plaintiff or Filing Attorney Information: Name lan Linker, Esq, NJ Attorney ID Number 181322019 Address 71 Barrington Road Ridgewood, NUOZ450 Email Address djanlinker2012@gmail.com Telephone Number (646) (646) 529-759 529-75933 ext. ext. Superior Court of New Jersey Law Division Bergen County Great.Group Home Improvement LLC. DocketNumber S(C- 1196-25 Plaintiff, Vv. Civil Action Jenna Winston Order Defendant(s), This matter having been brought before the Court on Motion of O plaintiff /K] defendant for an Order (describe relief requested): Transferring the above captioned matter to the Law Division from the Special Civil Part - Small Claims Section, (Docket No. SC 1195-23), because the damages sought by Defendant's and granting Defendant's request to file the proposed counterclaim attached to her certification in support of the instant motion. and the Court having considered the matter and for good cause appearing, On this day of 20. )__, itis ORDERED as follows: The Court grants Defendant's motion to transfer to this Court from the Special Civil Part - Small Claims Section, Docket No. SC 1195-23, because the damages sought by Defendant: proposed counterclaim exceed $20,000. The Court further grants Defendant's request to file the proposed counterlclaim attached t her Certification in support of the instant motion. The instant matter is no longer pending in the Small Claims Section. A new docket number shall be assigned. D Opposed 0 Unopposed ee J.S.C Revised 08/15/2022, CN 10555 page 14 of 14 BE Ao ea 02/23/2024 Pglof10 Trans ID: LCV2024489605 J enna Winston 71 Barrington Road Ridgewood, NJ 07450 jenna.winstonparsley@gmail.com (610) 564-3940 Superior Court of New Jersey Law Division Bergen County Docket No. Great Group Home Improvement LLC, Plaintiff, Civil Action Vv. Counterclaim Jenna Winston, Defendant Pursuant to R. 4:7, Defendant Jenna Winston, a/k/a Jenna Linker (“Linker”), files this counterclaim against Plaintiff Great Group Home Improvement LLC (the “Contractor”) and alleges as follows: PRELIMINARY STATEMENT 1 After preparing and signing a contract, omitting information mandated by and in violation of New Jersey law, in which the Plaintiff contractor agreed to undertake certain home improvements in the Defendant’s home, he performed shoddy work, consequently wasting thousands of dollars in materials provided by the Defendant, flooded the Defendant’s basement with concrete destroying the Defendant’s washing machine and basement floor, spilled concrete and debris on the Defendant’s outside walkway, and quit the job after demolishing the Defendant’s only bathroom on the main level, leaving her and her family of four children without a bathroom on that level. He quit the job before completing the agreed upon work, apparently because he did not like getting feedback from the Defendant or her husband about the quality of his work. He demanded partial payment after quitting, even though the contract said nothing ot eae 02/23/2024 Pg2of10 Trans ID: LCV2024489605 ' about partial payment or any payment before the work was complete. He agreed to replace the Defendant’s washing machine, which he acknowledged was broken, and then retracted the offer when the Defendant refused to make a partial payment. The Plaintiff breached the contract, was negligent, which damaged the Defendant’s property, and repeatedly violated New Jersey’s Consumer Fraud Act. Plaintiff should pay treble damages and the Defendants costs. FACTUAL ALLEGATIONS 2, On November 13, 2023, the parties signed a contract, in which plaintiff Great Group Home Improvement LLC (the “Contractor”) agreed to undertake certain work set forth therein and the homeowner defendant, Jenna Winston, a/k/a Jenna Linker (“Linker”), agreed to pay the Contractor $9,500 to complete the work (“Contract”). To keep costs down, Linker agreed to purchase the materials separately. The Contract is attached hereto as Exhibit “A”. 3 The scope of work included removing the molding trim through most of the main level of Linker’s home, including the main level bathroom, and replacing it with a PVC trim (Unbeknownst to Linker, the trim the Contractor’s representative recommended is typically used for exterior projects), replacing four interior doors on the main level, removing and replacing floor tile in the main level bathroom (the only bathroom on the main level), and removing and replacing the toilet and vanity in the main level bathroom, and cleaning up debris. 4 The Contractor took measurements and instructed Linker how much molding to purchase and the dimensions of the four doors she needed to buy. 5 The Contract did not state that Linker owed the Contractor a deposit or a partial payment at various points during the course of the project. The Contract also did not give the Contractor the right to cancel the Contract or quit the job before he completed the work and demand a ot eimnees 02/23/2024 Pg3o0f10 Trans ID: LCV2024489605 partial payment for labor. In fact, the Contract said nothing about an hourly rate for labor. It merely said the Contractor would provide labor. 6 The Contract also did not provide the legal name and address of the Contractor’s representative, who signed the Contract on the Contractor’s behalf, who was Linker’s primary point of contact, nor did it provide a start and end date or include a copy of the certificate of the Contractor’s general liability insurance. 7 The Contractor began the work on November 14, 2023. He typically had one worker with him. Occasionally he brought a second. He removed the existing floor tile, the vanity, and the toilet, and removed the existing molding in the bathroom and throughout the main level of Linker’s home. 8 During this early phase of the project, significant amounts of debris from the bathroom fell through the floor into Linker’s basement laundry room. After Linker’s husband notified the Contractor about the debris, he cleaned up the basement and covered the floor and the laundry machines with plastic. 9 The Contractor damaged walls while removing the molding in the living room, causing significant damage to one and minor damage to a second. The Contractor’s workers cut molding in Linker’s yard, spraying white PVC dust in the flower beds and on the walkways while they cut. The Contractor hung molding. The work was substandard throughout. 10. One of the Contractor’s workers cut and hung the molding around the entry way between Linker’s den and living room apparently without considering how she wanted the molding cut. The Contractor agreed and took down the molding. In multiple locations, the molding work looked like the workers had simply cut the right length and slapped it up onto the wall, including on the entry way between the kitchen and the dining room where the trim was cut wider on one BER--001188-24 02/23/2024 Pg4of10 Trans ID: LCV2024489605 side than the other, apparently to hide the holes in the wall that the Contractor had caused when he pulled off the old molding on that side. Another example of the shoddy workmanship was on the bathroom doorway. There, they cut the molding in a way that caused the doorway to be an inch and a half to two inches narrower than it had been before, making entry a challenge. Linker and her husband showed the Contractor these and other locations where the molding had been hung sloppily or without considering how Linker wanted the molding cut and hung. On each occasion, the Contractor agreed and said he would remove the molding and cut and hang it again. qi, The Contractor and his workers began to lay the bathroom floor tile. Per the Contractor’s advice, Linker purchased six boxes of tile to complete the six foot by nine foot rectangular bathroom. The Contractor never said anything about the type of tile Linker purchased at any time after she purchased it. 12. By November 20, 2023, although the Contractor had not completed the tile work in the bathroom, it was clear that this work was also substandard. Placing a level on the tiled floor showed how unlevel the work was. In fact, in at least one spot, the tile the Contractor put down was so bad, there was a visible space between the level and the tile. Further, there were noticeable uneven ridges in several spots on the newly tiled floor. The Contractor agreed the work was unacceptable and removed the tile. Linker purchased additional tile for $713 to replace the tile wasted by the Contractor’s poor workmanship. 13. Two days later, without telling Linker or her husband what the Contractor intended to do or that he intended to use self-leveling concrete in the bathroom before his second attempt to lay the floor tile, he poured concrete onto the bathroom floor after mixing it and spilling it on the front walkway. Because Linker did not know what the Contractor had planned, she had briefly pulled back the plastic sheet that the Contractor had put down in the basement, so her family SER Race 02/23/2024 Pg5of10 Trans ID: LCV2024489605 sould use ‘is laundry machines. Knowing how much debris had fallen through the floor into the basement when he demolished the bathroom, the Contractor should have known that the concrete would flood the basement. The liquid concrete landed on and ran into Linker’s one year old LG brand washing machine and in multiple spots on the basement floor. 14. Linker’s husband attempted to salvage the washing machine. When he told the Contractor about the concrete flood, the Contractor, who apparently realized that running a washing machine damaged by a significant quantity of concrete was unwise, asked Linker’s husband not to use the machine. The Contractor accepted responsibility for the machine and initially said he would replace it. Linker did not use the machine until she and her husband tested it on November 27. During the test, water began leaking immediately from the bottom of the machine. Linker’s husband, who had recorded the test, stayed to watch, turned off the machine and cleaned up the water. 15. Linker had been sending out the family’s laundry since the Contractor broke their washing machine. Early on November 27, Linker’s husband texted the Contractor’s representative, Mike: “Good morning, I sent you the washing machine model number. When is it supposed to be delivered?” 16. Mike responded: “Good morning It is coming on December 15” Ws Linker’s husband texted back: “Okay. While I certainly appreciate that you ordered it already, it costs us more than $90 a week to send out our laundry.” (There are six people living in Linker’s home.) BER es 02/23/2024 Pg6of10 Trans ID: LCV2024489605 18, Bven though he had previously said not to use the machine and had not sent over someone to determine whether the machine was broken, Mike said: Use yours until is delivered It is not broken We need a payment today for $5500 Please thank you. I appreciate it. 19. Linker’s husband responded: “Okay. What kind of caulk should we get?” 20. Mike replied: “White caulking for molding You can ask them and they will show it” 21, Linker’s husband then said: “We’re buying it online. What kind of caulking?” 22. Mike did not respond to this question. 23. Instead, with a demolished bathroom, poorly hung, unpainted, and unsealed molding, and sections of the main level bare and without any molding, the Contractor’s representative Mike notified Linker’s husband after the above exchange also by text message on November 27, 2023, that he was “discontinuing” the work, i.e., quitting the job, because according to him, he was “losing a lot of money.” The Contractor was apparently concerned that Linker would continue objecting to his substandard work. 24. He stated: As of today you owe us $5500 + [] $450 that I “payed for your materials and the work that was done -$1800 your washing machine -$700 for your tiles You owe us $4450 Pee ee 02/23/2024 Pg7of10 Trans ID: LCV2024489605 25, A lengthy exchange where Mike, on behalf of the Contractor, attempted to persuade Linker’s husband to pay him $5,000, or $3,000 if he cleaned up the mess he left, even refusing to replace the washing machine if Linker did not agree to pay him. 26. Linker found another contractor to address the shoddy work, order new materials, and complete the job properly. The new contractor agreed to complete the job for $9,600, or $100 more than the Contractor requested to complete the job. The new contractor requested 50 percent of the payment half-way through the job. CAUSES OF ACTION FIRST CAUSE OF ACTION — BREACH OF CONTRACT 27. Linker incorporates paragraphs 1-26 as if restated fully herein. 28. Linker and the Contractor entered into a contract on November 13, 2023, in which the Contractor agreed to undertake a specific list of home repairs and Linker agreed to pay the Contractor $9,500 in exchange for this work. 29. The contract between Linker and the Contractor did not say that Linker would owe a partial payment or any payment prior to completion of the work. 30. The Contractor quit the job before he completed the work and demanded partial payment in breach of contract. 31s As a result of the Contractor’s breach, Linker has been damaged. 32. Linker paid for the materials under the contract and lost $1,804.45 for the wasted and improper molding, $713.06 for the tile the Contractor wasted, and an additional $5,000 to fix the Contractor’s substandard work. SECOND CAUSE OF ACTION — NEGLIGENCE 33. Linker incorporates paragraphs 1-32 as if restated fully herein. A eae 02/23/2024 Pg 8of10 Trans ID: LCV2024489605 34, It was foreseeable that using Linker’s front paver walkway as a staging area to mix concrete and to cut PVC trim could cause damage to the walkway and the adjacent flower beds. Thus, the Contractor owed Linker a duty of care. 35. It was also foreseeable that pouring liquid concrete onto the bathroom floor could cause damage to the basement, because when the Contractor demolished the bathroom significant quantities of concrete chunks and debris fell into the basement. Thus, the Contractor owed Linker a duty of care. 36. The Contractor spilled concrete on the walkway and the white PVC dust stained and damaged Linker’s walkway. 37. Because it was reasonably foreseeable that mixing concrete and using a power saw on white PVC on a paver stone walkway would cause damage thereto, the Contractor’s negligence was the proximate cause of the damage to Linker’s walkway. 38. The Contractor poured concrete onto the bathroom and it spilled into the basement several days after the Contractor had spread a plastic cover over the washing machine. However, he did not notify Linker that he intended to pour liquid onto the bathroom floor or take any steps to ensure that the plastic cover was still in place protecting the washing machine. The Contractor’s negligence caused damage to the washing machine and Linker’s laundry room floor. 39. Because it was reasonably foreseeable that pouring concrete onto a floor that had previously dropped significant quantities of debris into the basement would cause damage thereto and to the washing machine, the Contractor’s negligence and failure to communicate with Linker about his intention to pour concrete into such a room, was the proximate cause of the damage to Linker’s washing machine and her laundry room floor. BER ene 02/23/2024 Pg9of10 Trans ID: LCV2024489605 40. The senching machine cost $1,999 to replace plus $132.43 in tax, or $2,131.43. The replacement machine is comparable to the machine the Contractor damaged. 41. While Linker was without a washing machine, she was damaged in the amount of $309.20 to send out her and her family’s laundry. THIRD CAUSE OF ACTION — CONSUMER FRAUD ACT 42. Linker incorporates paragraphs 1-41 as if restated fully herein. 43. The Contractor violated the New Jersey Consumer Fraud Act, and New Jersey’s Administrative Code incorporated therein. Linker suffered a loss therefrom. And the Contractor’s conduct caused said losses. Accordingly, the Contractor should pay Linker treble damages plus costs. 44. The Contractor violated the CFA as follows: He performed substandard work as described above; He demanded partial payment before completing the work; He quit the job before completing the work; He knowingly failed to disclose that he expected a partial payment before completing the work, which rendered untrue, or at a minimum misleading, the contract, which contained no provision for a partial payment (NJAC § 13:45A-16.2(9)(ii)); The contract failed to disclose, and the Contractor failed to mention that he required a partial payment before completion (NJ Rev Stat § 56:8-151(3) (2022); NJAC § 13:45A-16.2(6)(vi)); The contract failed to provide the legal name and business address of the Contractor’s representative, who negotiated and signed the contract (NJAC § 13:45A-16.2(12)(i)); BER ert ers 02/23/2024 Pg10o0f10 Trans ID: LCV2024489605 2. The contract failed to disclose the dates on which the work was to begin and end by the Contractor (NJAC § 13:45A-16.2(12)(iv)); The contract failed to include a copy of the certificate of commercial general liability insurance (NJAC § 13:45A-16)); The contract failed to clearly disclose the total price to be paid by Linker, including partial payments for incomplete work and hourly labor charges (NJAC § 13:45A- 16.2(12)(iii)). 45. The Contractor’s violations caused the losses Linker sustained as alleged herein. WHEREFORE, Defendant Jenna Winston, a/k/a Jenna Linker respectfully requests a judgment against Plaintiff Great Group Home Improvement LLC for treble damages, or $28,946.82, plus costs. Jenna Wi on, Dated: January 1, 2024 10 BERL-001188-24 02/23/2024 Pglof8 Trans ID: LCV2024489605 EXHIBIT BER-L-001188-24 02/23/2024 Pg2of8 Trans ID: LCV2024489605 INVOIKC I t Bill To ‘is Jenna Winston “GREAT GROUP 71 Barrington Rd Nowe tuPRoveMenT ite Ridgewood, Nj 07450 (610) 564-3940 Great Group Home Improvement LLC Payment terms Due upon receipt Invoice # 16671 231 Columbus Pl Cliffside Park, Nj 07010 Date 11/13/2023 Phone: (973) 262-2641 Email: greatgrouphomeimprovement@gmail.com Web: greatgrouphomeimprovementllc.com Description Exterior & Interior * Replace 7 baseboard covers x 6’ each L + Replace 4 baseboard for heating 63”L + Replace 60’ L x 8"W base trim + Replace 1x8”x8'x 23’ + Replace 28’ of 1x6x8’ + Replace 1 piece x1x2x8’ 2, Replace Same measures another door way as above . * Replace 1 door 28x80” * Replace 2 door 32x80” + Replace 1x5”x 20' of base molding * Replace 1 vanity in the bathroom * Replace 1 toilet in the bathroom * Replace Bathroom tiles 6'x9' in the bathroom * Clean up Debris + All material provided by the client + Labor is provided by our company Subtotal $9,500.00 Total $9,500.00 Page 1 of6 BER-L-001188-24 02/23/2024 Pg3o0f8 Trans ID: LCV2024489605 Lic#13VH121 07700 Page 2 of 6 7 \ ) Ct, A] i = Page 3 of 6 BER-L-001188-24 02/23/2024 Pg5of8 Trans ID: LCV2024489605 I |t ay _| | I a cs al i» i 1 | — 1 Page 4 of 6 oy : vi ij | \| \ Ah aaa Page 5 of6 BER-L-001188-24 02/23/2024 Pg7of8 Trans ID: LCV2024489605 Pua, Lit oe ees es ‘signed on: 1113/2023 Signed on: 11/13/2023 Great Group Home Improvement LLC Jenna Winston Page 6 of6 BER-L-001188-24 02/23/2024 Pg 8of8 Trans ID: LCV2024489605 ‘ Form C Plaintiff O Check if new address/phone number Name Great Group Home Improvement llc Superior Court of New Jersey Address Law Division, Special Civil Part Bergen County Email Address Docket Number SC-1195-23 Telephone Number ext. vs. Defendant O Check if new address/phone number Civil Action Name Jenna Winston Address 71 Barrington Road Order Ridgewood, NJ 07450 Email Address jenna.winstonparsle mail.com Telephone Number (610) 564-3940" ext. i This matter being opened to the court by, Jenna Winston , (your name) the D Plaintiff / Defendant in the case by way of motion seeking an order to: Permit Discdvery O1 Amend Judgment O Vacate Dismissal/Reinstate Complaint O Enter Judgment Out of Time O Amend Complaint O Vacate Default/Vacate Default Judgment O Amend Answer HM Other (Specify) Transfer to law and the court having considered the motion, pleadings on file and/or argument of the moving party and for good cause appearing; (Do not write below this line, for court use only) On this day of > 20__, it is ORDERED that: It is FURTHER ORDERED that a copy of this Order be served by the moving party upon all other parties or their attorneys, if any, within days of the date listed above. This motion was: O Opposed 01 Unopposed Revised 08/03/2022, CN 10543 page 11 of 11