Preview
CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 1 of 5 Trans ID: LCV2024672415
ZAFRAN LAW GROUP
By: Jonathan A. Fendler, Esq.
Attorney ID No: 170232015
314 Cherry Avenue
Voorhees, NJ 08043
Phone: (215) 587-0038
Fax: (215) 587-0030
Email: jonf@jaredzafranlaw.com
Attorney for Plaintiff, Alexa Allen
ALEXA ALLEN : SUPERIOR COURT OF NEW JERSEY
Plaintiff : LAW DIVISION –
: CAMDEN COUNTY
v. :
: DOCKET NO.:
LAUREN SERPINETO, :
JOHN DOE #1-10 (fictitious), and : Civil Action
ABC Corp., #1-10 (fictitious) :
: COMPLAINT AND
Defendant(s) : DEMAND FOR JURY TRIAL
Plaintiff, Alexa Allen, an adult individual currently residing at 11 Essex Court in the
community of Marlton, Township of Evesham, County of Burlington, State of New Jersey, by
and through her attorney, Zafran Law Group, says:
FIRST COUNT
Alexa Allen v. Lauren Serpineto
1. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle
traveling southbound in the left lane of S. Church Street approaching its intersection with
Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New
Jersey, while the Defendant, Lauren Serpineto, was operating a motor vehicle also
traveling southbound in the left lane of S. Church Street approaching its intersection with
Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New
Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa
Allen.
2. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete
stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the
steady red traffic signal then facing her and controlling the aforesaid intersection.
3. At the aforesaid time and place, the Defendant, Lauren Serpineto, for reasons unknown,
disregarded the traffic conditions then present approaching the intersection of S. Church
Street and Birchfield Drive, including the stopped motor vehicle operated by Plaintiff as a
result of the steady red traffic signal then controlling the aforesaid intersection, and in so
doing, collided with the rear of the stopped motor vehicle operated by Plaintiff, Alexa
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Allen.
4. The Defendant, Lauren Serpineto, failed to maintain control of her vehicle, causing
injuries to the Plaintiff.
5. The Defendant, Lauren Serpineto, did so carelessly, recklessly, and negligently operate a
motor vehicle resulting in injuries to the Plaintiff.
6. As a result of the acts and/or omissions of the Defendant, Lauren Serpineto, Plaintiff,
Alexa Allen, sustained diverse personal injuries of both a permanent and temporary
nature, endured and will endure great pain, have been and will be compelled to expend
large sums of money for physicians and other help in an attempt to cure Plaintiff’s said
injuries, have been and will be prevented from attending to Plaintiff’s normal business
and affairs, and have been otherwise damaged.
WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant,
Lauren Serpineto, for such sums as would reasonably and properly compensate Plaintiff in
accordance with the laws of the State of New Jersey, together with interest and cost of suit.
SECOND COUNT
Alexa Allen v. John Doe #1-10 (fictitious)
1. Plaintiff repeats each and every allegation in the First Count of this Complaint as though
set forth at length herein.
2. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle
traveling southbound in the left lane of S. Church Street approaching its intersection with
Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New
Jersey, while the Defendant, John Doe #1-10 (fictitious), was operating a motor vehicle
also traveling southbound in the left lane of S. Church Street approaching its intersection
with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of
New Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa
Allen.
3. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete
stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the
steady red traffic signal then facing her and controlling the aforesaid intersection.
4. At the aforesaid time and place, the Defendant, John Doe #1-10 (fictitious), for reasons
unknown, disregarded the traffic conditions then present approaching the intersection of
S. Church Street and Birchfield Drive, including the stopped motor vehicle operated by
Plaintiff as a result of the steady red traffic signal then controlling the aforesaid
intersection, and in so doing, collided with the rear of the stopped motor vehicle operated
by Plaintiff, Alexa Allen.
5. The Defendant, John Doe #1-10 (fictitious), failed to maintain control of their vehicle,
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causing injuries to the Plaintiff.
6. The Defendant, John Doe #1-10 (fictitious), did so carelessly, recklessly, and negligently
operate a motor vehicle resulting in injuries to the Plaintiff.
7. As a result of the acts and/or omissions of the Defendant, John Doe #1-10 (fictitious),
Plaintiff, Alexa Allen, sustained diverse personal injuries of both a permanent and
temporary nature, endured and will endure great pain, have been and will be compelled to
expend large sums of money for physicians and other help in an attempt to cure
Plaintiff’s said injuries, have been and will be prevented from attending to Plaintiff’s
normal business and affairs, and have been otherwise damaged.
WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant, John
Doe #1-10 (fictitious), for such sums as would reasonably and properly compensate Plaintiff in
accordance with the laws of the State of New Jersey, together with interest and cost of suit.
THIRD COUNT
Alexa Allen v. ABC Corp. #1-10 (fictitious)
1. Plaintiff repeats each and every allegation in the First and Second Counts of this
Complaint as though set forth at length herein.
2. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle
traveling southbound in the left lane of S. Church Street approaching its intersection with
Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New
Jersey, while the Defendant, ABC Corp. #1-10 (fictitious), was operating a motor vehicle
also traveling southbound in the left lane of S. Church Street approaching its intersection
with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of
New Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa
Allen.
3. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete
stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the
steady red traffic signal then facing her and controlling the aforesaid intersection.
4. At the aforesaid time and place, the Defendant, ABC Corp. #1-10 (fictitious), for reasons
unknown, disregarded the traffic conditions then present approaching the intersection of
S. Church Street and Birchfield Drive, including the stopped motor vehicle operated by
Plaintiff as a result of the steady red traffic signal then controlling the aforesaid
intersection, and in so doing, collided with the rear of the stopped motor vehicle operated
by Plaintiff, Alexa Allen.
5. The Defendant, ABC Corp. #1-10 (fictitious), failed to maintain control of their vehicle,
causing injuries to the Plaintiff.
6. The Defendant, ABC Corp. #1-10 (fictitious), did so carelessly, recklessly, and
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negligently operate a motor vehicle resulting in injuries to the Plaintiff.
7. As a result of the acts and/or omissions of the Defendant, ABC Corp. #1-10 (fictitious),
Plaintiff, Alexa Allen, sustained diverse personal injuries of both a permanent and
temporary nature, endured and will endure great pain, have been and will be compelled to
expend large sums of money for physicians and other help in an attempt to cure
Plaintiff’s said injuries, have been and will be prevented from attending to Plaintiff’s
normal business and affairs, and have been otherwise damaged.
WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant, ABC
Corp. #1-10 (fictitious), for such sums as would reasonably and properly compensate Plaintiff in
accordance with the laws of the State of New Jersey, together with interest and cost of suit.
FOURTH COUNT
1. Plaintiff repeats each and every allegation in the First, Second, and Third Counts of this
Complaint as though set forth at length herein.
WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant(s),
Lauren Serpineto, John Doe #1-10 (fictitious), ABC Corp., #1-10 (fictitious), individually,
jointly, severally and in the alternative, for such sums as would reasonably and properly
compensate the Plaintiff under the laws of the State of New Jersey, together with interest and the
costs of suit.
DEMAND FOR JURY
PLEASE TAKE NOTICE that the Plaintiff hereby demands a jury trial as to all of the
within issues.
DEMAND FOR DISCOVERY OF INSURANCE COVERAGE
Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned
whether there are any insurance agreements or policies under which any person or entity carrying
on an insurance business may be liable to satisfy part or all of a judgment which may be entered
in this action or to indemnify or reimburse for payments made to satisfy the judgment.
If so, provide to the undersigned a copy of each policy or agreement, or in the alternative
state, under oath or certification; (a) policy number; (b) name and address of insurer; (c)
inception and expiration dates; (d) names and addresses of all persons/entities covered; (e)
personal injury limits; (f) property damage limits; (g) medical payment limits.
NOTICE OF NO OTHER ACTION
Pursuant to Rule 4:5-1 the Plaintiff’s Attorney hereby certifies to the best of his
knowledge that there is no other action or arbitration pending in which the matter in controversy
is the subject.
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DESIGNATION OF TRIAL COUNSEL
PLEASE TAKE NOTICE that Jonathan A. Fendler, Esquire, is hereby designated trial
counsel on behalf of Zafran Law Group, Attorney for Plaintiff, Alexa Allen.
/s/ Jonathan A. Fendler, Esquire
DATED: 03/14/2024 Jonathan A. Fendler, Esquire
Attorney for Plaintiff, Alexa Allen
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Civil Case Information Statement
Case Details: CAMDEN | Civil Part Docket# L-000800-24
Case Caption: ALLEN ALEXA VS SERPIENTO LAUREN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
Case Initiation Date: 03/14/2024 VERBAL THRESHOLD)
Attorney Name: JONATHAN A FENDLER Document Type: Complaint with Jury Demand
Firm Name: JARED S. ZAFRAN, LLC Jury Demand: YES - 6 JURORS
Address: 1500 WALNUT ST STE 500 Is this a professional malpractice case? NO
PHILADELPHIA PA 19102 Related cases pending: NO
Phone: 2155870038 If yes, list docket numbers:
Name of Party: PLAINTIFF : Allen, Alexa Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO
(if known): Unknown Does this case involve claims related to COVID-19? NO
Are sexual abuse claims alleged by: Alexa Allen? 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)
03/14/2024 /s/ JONATHAN A FENDLER
Dated Signed
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Preview
CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 1 of 5 Trans ID: LCV2024672415 ZAFRAN LAW GROUP By: Jonathan A. Fendler, Esq. Attorney ID No: 170232015 314 Cherry Avenue Voorhees, NJ 08043 Phone: (215) 587-0038 Fax: (215) 587-0030 Email: jonf@jaredzafranlaw.com Attorney for Plaintiff, Alexa Allen ALEXA ALLEN : SUPERIOR COURT OF NEW JERSEY Plaintiff : LAW DIVISION – : CAMDEN COUNTY v. : : DOCKET NO.: LAUREN SERPINETO, : JOHN DOE #1-10 (fictitious), and : Civil Action ABC Corp., #1-10 (fictitious) : : COMPLAINT AND Defendant(s) : DEMAND FOR JURY TRIAL Plaintiff, Alexa Allen, an adult individual currently residing at 11 Essex Court in the community of Marlton, Township of Evesham, County of Burlington, State of New Jersey, by and through her attorney, Zafran Law Group, says: FIRST COUNT Alexa Allen v. Lauren Serpineto 1. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, while the Defendant, Lauren Serpineto, was operating a motor vehicle also traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa Allen. 2. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the steady red traffic signal then facing her and controlling the aforesaid intersection. 3. At the aforesaid time and place, the Defendant, Lauren Serpineto, for reasons unknown, disregarded the traffic conditions then present approaching the intersection of S. Church Street and Birchfield Drive, including the stopped motor vehicle operated by Plaintiff as a result of the steady red traffic signal then controlling the aforesaid intersection, and in so doing, collided with the rear of the stopped motor vehicle operated by Plaintiff, Alexa CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 2 of 5 Trans ID: LCV2024672415 Allen. 4. The Defendant, Lauren Serpineto, failed to maintain control of her vehicle, causing injuries to the Plaintiff. 5. The Defendant, Lauren Serpineto, did so carelessly, recklessly, and negligently operate a motor vehicle resulting in injuries to the Plaintiff. 6. As a result of the acts and/or omissions of the Defendant, Lauren Serpineto, Plaintiff, Alexa Allen, sustained diverse personal injuries of both a permanent and temporary nature, endured and will endure great pain, have been and will be compelled to expend large sums of money for physicians and other help in an attempt to cure Plaintiff’s said injuries, have been and will be prevented from attending to Plaintiff’s normal business and affairs, and have been otherwise damaged. WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant, Lauren Serpineto, for such sums as would reasonably and properly compensate Plaintiff in accordance with the laws of the State of New Jersey, together with interest and cost of suit. SECOND COUNT Alexa Allen v. John Doe #1-10 (fictitious) 1. Plaintiff repeats each and every allegation in the First Count of this Complaint as though set forth at length herein. 2. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, while the Defendant, John Doe #1-10 (fictitious), was operating a motor vehicle also traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa Allen. 3. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the steady red traffic signal then facing her and controlling the aforesaid intersection. 4. At the aforesaid time and place, the Defendant, John Doe #1-10 (fictitious), for reasons unknown, disregarded the traffic conditions then present approaching the intersection of S. Church Street and Birchfield Drive, including the stopped motor vehicle operated by Plaintiff as a result of the steady red traffic signal then controlling the aforesaid intersection, and in so doing, collided with the rear of the stopped motor vehicle operated by Plaintiff, Alexa Allen. 5. The Defendant, John Doe #1-10 (fictitious), failed to maintain control of their vehicle, CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 3 of 5 Trans ID: LCV2024672415 causing injuries to the Plaintiff. 6. The Defendant, John Doe #1-10 (fictitious), did so carelessly, recklessly, and negligently operate a motor vehicle resulting in injuries to the Plaintiff. 7. As a result of the acts and/or omissions of the Defendant, John Doe #1-10 (fictitious), Plaintiff, Alexa Allen, sustained diverse personal injuries of both a permanent and temporary nature, endured and will endure great pain, have been and will be compelled to expend large sums of money for physicians and other help in an attempt to cure Plaintiff’s said injuries, have been and will be prevented from attending to Plaintiff’s normal business and affairs, and have been otherwise damaged. WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant, John Doe #1-10 (fictitious), for such sums as would reasonably and properly compensate Plaintiff in accordance with the laws of the State of New Jersey, together with interest and cost of suit. THIRD COUNT Alexa Allen v. ABC Corp. #1-10 (fictitious) 1. Plaintiff repeats each and every allegation in the First and Second Counts of this Complaint as though set forth at length herein. 2. On or about October 13, 2022, Plaintiff, Alexa Allen was operating a motor vehicle traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, while the Defendant, ABC Corp. #1-10 (fictitious), was operating a motor vehicle also traveling southbound in the left lane of S. Church Street approaching its intersection with Birchfield Drive, in the Township of Mount Laurel, County of Burlington, State of New Jersey, and positioned directly behind the motor vehicle operated by Plaintiff, Alexa Allen. 3. At the aforesaid time and place, Plaintiff, Alexa Allen, came to a controlled and complete stop in the left lane of S. Church Street at its intersection with Birchfield Drive due to the steady red traffic signal then facing her and controlling the aforesaid intersection. 4. At the aforesaid time and place, the Defendant, ABC Corp. #1-10 (fictitious), for reasons unknown, disregarded the traffic conditions then present approaching the intersection of S. Church Street and Birchfield Drive, including the stopped motor vehicle operated by Plaintiff as a result of the steady red traffic signal then controlling the aforesaid intersection, and in so doing, collided with the rear of the stopped motor vehicle operated by Plaintiff, Alexa Allen. 5. The Defendant, ABC Corp. #1-10 (fictitious), failed to maintain control of their vehicle, causing injuries to the Plaintiff. 6. The Defendant, ABC Corp. #1-10 (fictitious), did so carelessly, recklessly, and CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 4 of 5 Trans ID: LCV2024672415 negligently operate a motor vehicle resulting in injuries to the Plaintiff. 7. As a result of the acts and/or omissions of the Defendant, ABC Corp. #1-10 (fictitious), Plaintiff, Alexa Allen, sustained diverse personal injuries of both a permanent and temporary nature, endured and will endure great pain, have been and will be compelled to expend large sums of money for physicians and other help in an attempt to cure Plaintiff’s said injuries, have been and will be prevented from attending to Plaintiff’s normal business and affairs, and have been otherwise damaged. WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant, ABC Corp. #1-10 (fictitious), for such sums as would reasonably and properly compensate Plaintiff in accordance with the laws of the State of New Jersey, together with interest and cost of suit. FOURTH COUNT 1. Plaintiff repeats each and every allegation in the First, Second, and Third Counts of this Complaint as though set forth at length herein. WHEREFORE, Plaintiff, Alexa Allen, demands judgment against the Defendant(s), Lauren Serpineto, John Doe #1-10 (fictitious), ABC Corp., #1-10 (fictitious), individually, jointly, severally and in the alternative, for such sums as would reasonably and properly compensate the Plaintiff under the laws of the State of New Jersey, together with interest and the costs of suit. DEMAND FOR JURY PLEASE TAKE NOTICE that the Plaintiff hereby demands a jury trial as to all of the within issues. DEMAND FOR DISCOVERY OF INSURANCE COVERAGE Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned whether there are any insurance agreements or policies under which any person or entity carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or to indemnify or reimburse for payments made to satisfy the judgment. If so, provide to the undersigned a copy of each policy or agreement, or in the alternative state, under oath or certification; (a) policy number; (b) name and address of insurer; (c) inception and expiration dates; (d) names and addresses of all persons/entities covered; (e) personal injury limits; (f) property damage limits; (g) medical payment limits. NOTICE OF NO OTHER ACTION Pursuant to Rule 4:5-1 the Plaintiff’s Attorney hereby certifies to the best of his knowledge that there is no other action or arbitration pending in which the matter in controversy is the subject. CAM-L-000800-24 03/14/2024 11:12:15 AM Pg 5 of 5 Trans ID: LCV2024672415 DESIGNATION OF TRIAL COUNSEL PLEASE TAKE NOTICE that Jonathan A. Fendler, Esquire, is hereby designated trial counsel on behalf of Zafran Law Group, Attorney for Plaintiff, Alexa Allen. /s/ Jonathan A. Fendler, Esquire DATED: 03/14/2024 Jonathan A. Fendler, Esquire Attorney for Plaintiff, Alexa Allen CAM-L-000800-24 03/14/2024 CAM-L-000800-24 03/14/202411:12:15 11:12:15AM AM Pg 1 of 2 Trans TransID: ID:LCV2024672415 LCV2024672415 Civil Case Information Statement Case Details: CAMDEN | Civil Part Docket# L-000800-24 Case Caption: ALLEN ALEXA VS SERPIENTO LAUREN Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON- Case Initiation Date: 03/14/2024 VERBAL THRESHOLD) Attorney Name: JONATHAN A FENDLER Document Type: Complaint with Jury Demand Firm Name: JARED S. ZAFRAN, LLC Jury Demand: YES - 6 JURORS Address: 1500 WALNUT ST STE 500 Is this a professional malpractice case? NO PHILADELPHIA PA 19102 Related cases pending: NO Phone: 2155870038 If yes, list docket numbers: Name of Party: PLAINTIFF : Allen, Alexa Do you anticipate adding any parties (arising out of same Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO (if known): Unknown Does this case involve claims related to COVID-19? NO Are sexual abuse claims alleged by: Alexa Allen? 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) 03/14/2024 /s/ JONATHAN A FENDLER Dated Signed CAM-L-000800-24 03/14/2024 CAM-L-000800-24 03/14/202411:12:15 11:12:15AM AM Pg 2 of 2 Trans TransID: ID:LCV2024672415 LCV2024672415