Preview
ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 6 Trans ID: LCV2024695578
Jaffe Glenn Law Group, P.A.
300 Carnegie Center, Suite 150
Princeton, NJ 08540
Attorneys for Plaintiff
ALLAN TORRES,
SUPERIOR COURT OF NEW JERSEY
LAW DIV: ATLANTIC COUNTY
Plaintiff,
Dkt No.:
- against -
Jurisdiction for this Action is Based Upon
VEGA AUTO DETAILING, LLC Plaintiff’s address
and JONATHAN VEGA, individually
Defendants.
COMPLAINT
Plaintiff, by his attorneys, Jaffe Glenn Law Group, P.A., alleges upon knowledge to himself
and upon information and belief as to all other matters as follows:
1. This action is brought on behalf of Plaintiff Allan Torres, (“Plaintiff” or “Torres”)
who worked for Defendants Vega Auto Detailing, LLC (“Auto Detailing”) and Jonathan Vega,
individually (“Vega”) (hereinafter collectively referred to as “Defendants”), to recover statutory
overtime payments, which Plaintiff was entitled to receive for work he performed for and on
behalf of Defendants.
2. Plaintiff brings this lawsuit seeking recovery against Defendants for Defendants’
violations of the New Jersey State Wage and Hour Law, N.J.S.A. §34:11-56a et.seq. (“NJWHL”)
and the New Jersey Wage Payment Law, N.J.S.A. §34:11-4.1, et.seq. (“NJWPL”).
ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 2 of 6 Trans ID: LCV2024695578
PARTIES
3. Plaintiff “ is an adult individual who is a resident of Hammonton, Atlantic
County, New Jersey.
4. Plaintiff was employed by Defendants full-time, as a detailer and customer
service representative, from in or about March 2018 through February 2024.
5. Upon information and belief, the Defendants’ car wash is located in Hammonton,
Atlantic County, New Jersey.
6. Upon information and belief, at all times relevant to this Complaint, the
Defendants employed individuals to perform labor services on behalf of the Defendants.
7. Upon information and belief, Defendant Vega is a New Jersey state Resident.
8. Upon information and belief, at all times relevant to this Complaint, individual
Defendant Vega has been a partner, officer and/or manager of Defendant Auto Detailing.
9. Upon information and belief, at all times relevant to this Complaint, individual
Defendant Vega has had power over personnel decisions at the Defendant Auto Detailing,
including the management of day to day operations, control over employee pay practices and the
power to change same, and the power to hire and fire employees, set their wages, and otherwise
control the terms of their employment.
10. Jurisdiction lies in any court of competent jurisdiction. See New Jersey Statute
§34:11-66.
11. Venue lies in Atlantic County as the events that give rise to this Complaint arose
in Atlantic County and is the headquarters of the corporate Defendant. At all times material
hereto, Plaintiff performed non-exempt car detailing and customer relations for the Defendants
from their Hammonton, Atlantic County, New Jersey, car detailing business. Defendants are
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therefore within the jurisdiction and venue of this Court.
12. Based upon the information preliminarily available, and subject to discovery in
this cause, the Defendants did not properly compensate Plaintiff for all overtime worked in a
work week.
13. Plaintiff was an hourly employee and his most recent hourly rate of pay was
$18.00 per hour.
14. Plaintiff routinely worked six (6) days per week.
15. Plaintiff worked seventy (70) hours per week.
16. Plaintiff was not paid at the statutory rate of overtime pay for hours worked in a
work week in excess of forty (40).
17. It is Defendants’ widespread pattern, policy, and practice to violate the NJWHL
by failing to pay its workers at the required rate of compensation for their overtime hours worked
in excess of forty (40) in a workweek, as described in this Complaint.
18. At all times material hereto, Plaintiff was performing his duties for the benefit of
and on behalf of Defendants.
19. This cause of action is brought to recover from Defendants unpaid overtime
compensation, additional damages as prescribed in the statute, and costs and reasonable
attorneys’ fees under the provisions of the NJWHL, on behalf of Plaintiff during the material
time.
20. At all times pertinent to this complaint, Defendants failed to comply with N.J.S.A.
34:11-56a et.seq., in that Plaintiff performed services and labor for Defendants for which
Defendants made no provision to pay Plaintiff compensation to which he was lawfully entitled
for the time worked in excess of forty (40) hours within a work week.
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21. Plaintiff has retained the law office of Jaffe Glenn Law Group, P.A. to represent
him individually and incurred attorneys’ fees and costs in bringing this action. Pursuant to 29
U.S.C. § 216(b), Plaintiff is entitled to recovery of reasonable attorneys’ fees and costs.
FIRST COUNT
AGAINST THE DEFENDANTS
INDIVIDUALLY AND JOINTLY FOR
FAILURE TO PAY OVERTIME WAGES PURSUANT TO NJWHL
22. The Plaintiff repeats and re-alleges the allegations set forth above.
23. New Jersey Statute 34:12-56.61 concerning Overtime Wages provides that “for
each hour of working time in excess of 40 hours in any week, except as provided in N.J.A.C.
12:56-7.1, every employer shall pay to each of his employees, wages at a rate of not less than 1
½ times such employee’s regular hourly rate.”
24. Plaintiff is not exempt under N.J.A.C 12:56-7.1, and therefore, he is entitled to 1½
times her regular rate of pay for all of her hours worked in a workweek over forty (40).
25. As a result of Defendants’ violation, Plaintiff is entitled to unpaid wages,
liquidated damages, costs and reasonable attorneys’ fees as directed by statute.
SECOND COUNT
AGAINST THE DEFENDANTS
INDIVIDUALLY AND JOINTLY FOR
FAILURE TO PAY OVERTIME WAGES PURSUANT TO NJWPL
26. Plaintiff re-alleges and incorporates here by reference, all allegations contained in
the above paragraphs.
27. Defendants’ aforementioned conduct is in violation of New Jersey State Wage
Payment Law. N.J.S.A. 34:11- 4.1, et seq., in that the Defendants willfully failed to pay Plaintiff
for all hours worked.
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30. As a direct and proximate cause of Defendants’ actions, Plaintiff suffered
damages, including but not limited to past lost earnings.
48. As a result of Defendants’ violations, Plaintiff is entitled to liquidated damages,
costs and attorneys’ fees as directed pursuant to the NJWPL.
WHEREFORE, Plaintiff demands judgment for:
a. Damages;
b. Attorneys’ fees;
c. Costs of suit.
DESIGNATION OF TRIAL COUNSEL
ANDREW GLENN and JODI JAFFE are hereby designated as trial counsel for
the Plaintiff.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues involved herein pursuant to
R. 4:35-1.
Dated: March 17, 2024 JAFFE GLENN LAW GROUP, P.A.
By: /s Andrew I. Glenn
Andrew Glenn, Esq.
Jodi J. Jaffe, Esq.
300 Carnegie Center, Suite 150
Princeton, NJ 08540
Tel: 201-687-9977
Attorneys for Plaintiff
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RULE 4:5-1 CERTIFICATION
I hereby certify in accordance with R. 4:5-1 that to the best of my knowledge, there
are no other proceedings either pending or contemplated with respect to the matter in controversy
in this action and at this time there are no other parties known who should be joined in this action.
Dated: Princeton, New Jersey
March 17, 2024 JAFFE GLENN LAW GROUP, P.A.
By: /s/Andrew Glenn
Andrew I. Glenn, Esq.
300 Carnegie Center, Suite 150
Princeton, NJ 08540
Aglenn@jaffeglenn.com
Attorneys for Plaintiff
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SUMMONS
Attorney(s) Andrew I. Glenn, Esq.
Superior Court of
Office Address 300 Carnergie, Suite 150
Town, State, Zip Code Princeton, NJ 08540 New Jersey
Atlantic County
Telephone Number 2016879977 Law Division
Attorney(s) for Plaintiff Jaffe Glenn Law Group, P.A. Docket No:
Allan Torres,
Plaintiff(s)
CIVIL ACTION
vs. SUMMONS
Vega Auto Detailing, LLC, and
Jonanthan Vega, individually,
Defendant(s)
From The State of New Jersey To The Defendant(s) Named Above:
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached
to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written
answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days
from the date you received this summons, not counting the date you received it. (A directory of the addresses of each deputy
clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at
http://www.njcourts.gov.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof
of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing
fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy
clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your
answer or motion to plaintiff's attorney whose name and address appear above, or to plaintiff, if no attorney is named above.
A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and
completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for
the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your
money, wages or property to pay all or part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal
Services of New Jersey Statewide Hotline at 1-888-LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are
not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services.
A directory with contact information for local Legal Services Offices and Lawyer Referral Services is available in the Civil
Division Management Office in the county listed above and online at http://www.njcourts.gov.
Clerk of the Superior Court
DATED: 03/17/2024
Name of Defendant to Be Served: Vega Auto Detailing, LLC
Address of Defendant to Be Served: Jonathan Vega, 731 White House Pike, Hammonton, NJ 08037
Revised 11/17/2014, CN 10792-English (Appendix XII-A)
ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 1 Trans ID: LCV2024695578
SUMMONS
Attorney(s) Andrew I. Glenn, Esq.
Superior Court of
Office Address 300 Carnergie, Suite 150
Town, State, Zip Code Princeton, NJ 08540 New Jersey
Atlantic County
Telephone Number 2016879977 Law Division
Attorney(s) for Plaintiff Jaffe Glenn Law Group, P.A. Docket No:
Allan Torres,
Plaintiff(s)
CIVIL ACTION
vs. SUMMONS
Vega Auto Detailing, LLC, and
Jonanthan Vega, individually,
Defendant(s)
From The State of New Jersey To The Defendant(s) Named Above:
The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached
to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written
answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days
from the date you received this summons, not counting the date you received it. (A directory of the addresses of each deputy
clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at
http://www.njcourts.gov.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof
of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing
fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy
clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your
answer or motion to plaintiff's attorney whose name and address appear above, or to plaintiff, if no attorney is named above.
A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and
completed Case Information Statement) if you want the court to hear your defense.
If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for
the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your
money, wages or property to pay all or part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal
Services of New Jersey Statewide Hotline at 1-888-LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are
not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services.
A directory with contact information for local Legal Services Offices and Lawyer Referral Services is available in the Civil
Division Management Office in the county listed above and online at http://www.njcourts.gov.
Clerk of the Superior Court
DATED: 03/17/2024
Name of Defendant to Be Served: Jonathan Vega
Address of Defendant to Be Served: Jonathan Vega, 731 White House Pike, Hammonton, NJ 08037
Revised 11/17/2014, CN 10792-English (Appendix XII-A)
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AM Pg 1 of 1 Trans
TransID:
ID:LCV2024695578
LCV2024695578
Civil Case Information Statement
Case Details: ATLANTIC | Civil Part Docket# L-000500-24
Case Caption: TORRES ALLAN VS VEGA AUTO Case Type: EMPLOYMENT (OTHER THAN CEPA OR LAD)
DETAILING, LLC Document Type: Complaint with Jury Demand
Case Initiation Date: 03/18/2024 Jury Demand: YES - 12 JURORS
Attorney Name: ANDREW IRA GLENN Is this a professional malpractice case? NO
Firm Name: JAFFE GLENN LAW GROUP, PA Related cases pending: NO
Address: 300 CARNEGIE CTR STE 150 If yes, list docket numbers:
PRINCETON NJ 08540 Do you anticipate adding any parties (arising out of same
Phone: 2016879977 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Torres, Allan Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Allan Torres? 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? YES
If yes, is that relationship: Employer/Employee
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)
03/18/2024 /s/ ANDREW IRA GLENN
Dated Signed
Preview
ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 6 Trans ID: LCV2024695578 Jaffe Glenn Law Group, P.A. 300 Carnegie Center, Suite 150 Princeton, NJ 08540 Attorneys for Plaintiff ALLAN TORRES, SUPERIOR COURT OF NEW JERSEY LAW DIV: ATLANTIC COUNTY Plaintiff, Dkt No.: - against - Jurisdiction for this Action is Based Upon VEGA AUTO DETAILING, LLC Plaintiff’s address and JONATHAN VEGA, individually Defendants. COMPLAINT Plaintiff, by his attorneys, Jaffe Glenn Law Group, P.A., alleges upon knowledge to himself and upon information and belief as to all other matters as follows: 1. This action is brought on behalf of Plaintiff Allan Torres, (“Plaintiff” or “Torres”) who worked for Defendants Vega Auto Detailing, LLC (“Auto Detailing”) and Jonathan Vega, individually (“Vega”) (hereinafter collectively referred to as “Defendants”), to recover statutory overtime payments, which Plaintiff was entitled to receive for work he performed for and on behalf of Defendants. 2. Plaintiff brings this lawsuit seeking recovery against Defendants for Defendants’ violations of the New Jersey State Wage and Hour Law, N.J.S.A. §34:11-56a et.seq. (“NJWHL”) and the New Jersey Wage Payment Law, N.J.S.A. §34:11-4.1, et.seq. (“NJWPL”). ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 2 of 6 Trans ID: LCV2024695578 PARTIES 3. Plaintiff “ is an adult individual who is a resident of Hammonton, Atlantic County, New Jersey. 4. Plaintiff was employed by Defendants full-time, as a detailer and customer service representative, from in or about March 2018 through February 2024. 5. Upon information and belief, the Defendants’ car wash is located in Hammonton, Atlantic County, New Jersey. 6. Upon information and belief, at all times relevant to this Complaint, the Defendants employed individuals to perform labor services on behalf of the Defendants. 7. Upon information and belief, Defendant Vega is a New Jersey state Resident. 8. Upon information and belief, at all times relevant to this Complaint, individual Defendant Vega has been a partner, officer and/or manager of Defendant Auto Detailing. 9. Upon information and belief, at all times relevant to this Complaint, individual Defendant Vega has had power over personnel decisions at the Defendant Auto Detailing, including the management of day to day operations, control over employee pay practices and the power to change same, and the power to hire and fire employees, set their wages, and otherwise control the terms of their employment. 10. Jurisdiction lies in any court of competent jurisdiction. See New Jersey Statute §34:11-66. 11. Venue lies in Atlantic County as the events that give rise to this Complaint arose in Atlantic County and is the headquarters of the corporate Defendant. At all times material hereto, Plaintiff performed non-exempt car detailing and customer relations for the Defendants from their Hammonton, Atlantic County, New Jersey, car detailing business. Defendants are -2- ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 3 of 6 Trans ID: LCV2024695578 therefore within the jurisdiction and venue of this Court. 12. Based upon the information preliminarily available, and subject to discovery in this cause, the Defendants did not properly compensate Plaintiff for all overtime worked in a work week. 13. Plaintiff was an hourly employee and his most recent hourly rate of pay was $18.00 per hour. 14. Plaintiff routinely worked six (6) days per week. 15. Plaintiff worked seventy (70) hours per week. 16. Plaintiff was not paid at the statutory rate of overtime pay for hours worked in a work week in excess of forty (40). 17. It is Defendants’ widespread pattern, policy, and practice to violate the NJWHL by failing to pay its workers at the required rate of compensation for their overtime hours worked in excess of forty (40) in a workweek, as described in this Complaint. 18. At all times material hereto, Plaintiff was performing his duties for the benefit of and on behalf of Defendants. 19. This cause of action is brought to recover from Defendants unpaid overtime compensation, additional damages as prescribed in the statute, and costs and reasonable attorneys’ fees under the provisions of the NJWHL, on behalf of Plaintiff during the material time. 20. At all times pertinent to this complaint, Defendants failed to comply with N.J.S.A. 34:11-56a et.seq., in that Plaintiff performed services and labor for Defendants for which Defendants made no provision to pay Plaintiff compensation to which he was lawfully entitled for the time worked in excess of forty (40) hours within a work week. -3- ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 4 of 6 Trans ID: LCV2024695578 21. Plaintiff has retained the law office of Jaffe Glenn Law Group, P.A. to represent him individually and incurred attorneys’ fees and costs in bringing this action. Pursuant to 29 U.S.C. § 216(b), Plaintiff is entitled to recovery of reasonable attorneys’ fees and costs. FIRST COUNT AGAINST THE DEFENDANTS INDIVIDUALLY AND JOINTLY FOR FAILURE TO PAY OVERTIME WAGES PURSUANT TO NJWHL 22. The Plaintiff repeats and re-alleges the allegations set forth above. 23. New Jersey Statute 34:12-56.61 concerning Overtime Wages provides that “for each hour of working time in excess of 40 hours in any week, except as provided in N.J.A.C. 12:56-7.1, every employer shall pay to each of his employees, wages at a rate of not less than 1 ½ times such employee’s regular hourly rate.” 24. Plaintiff is not exempt under N.J.A.C 12:56-7.1, and therefore, he is entitled to 1½ times her regular rate of pay for all of her hours worked in a workweek over forty (40). 25. As a result of Defendants’ violation, Plaintiff is entitled to unpaid wages, liquidated damages, costs and reasonable attorneys’ fees as directed by statute. SECOND COUNT AGAINST THE DEFENDANTS INDIVIDUALLY AND JOINTLY FOR FAILURE TO PAY OVERTIME WAGES PURSUANT TO NJWPL 26. Plaintiff re-alleges and incorporates here by reference, all allegations contained in the above paragraphs. 27. Defendants’ aforementioned conduct is in violation of New Jersey State Wage Payment Law. N.J.S.A. 34:11- 4.1, et seq., in that the Defendants willfully failed to pay Plaintiff for all hours worked. -4- ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 5 of 6 Trans ID: LCV2024695578 30. As a direct and proximate cause of Defendants’ actions, Plaintiff suffered damages, including but not limited to past lost earnings. 48. As a result of Defendants’ violations, Plaintiff is entitled to liquidated damages, costs and attorneys’ fees as directed pursuant to the NJWPL. WHEREFORE, Plaintiff demands judgment for: a. Damages; b. Attorneys’ fees; c. Costs of suit. DESIGNATION OF TRIAL COUNSEL ANDREW GLENN and JODI JAFFE are hereby designated as trial counsel for the Plaintiff. JURY DEMAND Plaintiff hereby demands a trial by jury on all issues involved herein pursuant to R. 4:35-1. Dated: March 17, 2024 JAFFE GLENN LAW GROUP, P.A. By: /s Andrew I. Glenn Andrew Glenn, Esq. Jodi J. Jaffe, Esq. 300 Carnegie Center, Suite 150 Princeton, NJ 08540 Tel: 201-687-9977 Attorneys for Plaintiff -5- ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 6 of 6 Trans ID: LCV2024695578 RULE 4:5-1 CERTIFICATION I hereby certify in accordance with R. 4:5-1 that to the best of my knowledge, there are no other proceedings either pending or contemplated with respect to the matter in controversy in this action and at this time there are no other parties known who should be joined in this action. Dated: Princeton, New Jersey March 17, 2024 JAFFE GLENN LAW GROUP, P.A. By: /s/Andrew Glenn Andrew I. Glenn, Esq. 300 Carnegie Center, Suite 150 Princeton, NJ 08540 Aglenn@jaffeglenn.com Attorneys for Plaintiff -6- ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 2 Trans ID: LCV2024695578 ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 2 of 2 Trans ID: LCV2024695578 ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 1 Trans ID: LCV2024695578 SUMMONS Attorney(s) Andrew I. Glenn, Esq. Superior Court of Office Address 300 Carnergie, Suite 150 Town, State, Zip Code Princeton, NJ 08540 New Jersey Atlantic County Telephone Number 2016879977 Law Division Attorney(s) for Plaintiff Jaffe Glenn Law Group, P.A. Docket No: Allan Torres, Plaintiff(s) CIVIL ACTION vs. SUMMONS Vega Auto Detailing, LLC, and Jonanthan Vega, individually, Defendant(s) From The State of New Jersey To The Defendant(s) Named Above: The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (A directory of the addresses of each deputy clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff's attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and completed Case Information Statement) if you want the court to hear your defense. If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all or part of the judgment. If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal Services of New Jersey Statewide Hotline at 1-888-LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A directory with contact information for local Legal Services Offices and Lawyer Referral Services is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov. Clerk of the Superior Court DATED: 03/17/2024 Name of Defendant to Be Served: Vega Auto Detailing, LLC Address of Defendant to Be Served: Jonathan Vega, 731 White House Pike, Hammonton, NJ 08037 Revised 11/17/2014, CN 10792-English (Appendix XII-A) ATL-L-000500-24 03/18/2024 2:00:00 AM Pg 1 of 1 Trans ID: LCV2024695578 SUMMONS Attorney(s) Andrew I. Glenn, Esq. Superior Court of Office Address 300 Carnergie, Suite 150 Town, State, Zip Code Princeton, NJ 08540 New Jersey Atlantic County Telephone Number 2016879977 Law Division Attorney(s) for Plaintiff Jaffe Glenn Law Group, P.A. Docket No: Allan Torres, Plaintiff(s) CIVIL ACTION vs. SUMMONS Vega Auto Detailing, LLC, and Jonanthan Vega, individually, Defendant(s) From The State of New Jersey To The Defendant(s) Named Above: The plaintiff, named above, has filed a lawsuit against you in the Superior Court of New Jersey. The complaint attached to this summons states the basis for this lawsuit. If you dispute this complaint, you or your attorney must file a written answer or motion and proof of service with the deputy clerk of the Superior Court in the county listed above within 35 days from the date you received this summons, not counting the date you received it. (A directory of the addresses of each deputy clerk of the Superior Court is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov.) If the complaint is one in foreclosure, then you must file your written answer or motion and proof of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box 971, Trenton, NJ 08625-0971. A filing fee payable to the Treasurer, State of New Jersey and a completed Case Information Statement (available from the deputy clerk of the Superior Court) must accompany your answer or motion when it is filed. You must also send a copy of your answer or motion to plaintiff's attorney whose name and address appear above, or to plaintiff, if no attorney is named above. A telephone call will not protect your rights; you must file and serve a written answer or motion (with fee of $175.00 and completed Case Information Statement) if you want the court to hear your defense. If you do not file and serve a written answer or motion within 35 days, the court may enter a judgment against you for the relief plaintiff demands, plus interest and costs of suit. If judgment is entered against you, the Sheriff may seize your money, wages or property to pay all or part of the judgment. If you cannot afford an attorney, you may call the Legal Services office in the county where you live or the Legal Services of New Jersey Statewide Hotline at 1-888-LSNJ-LAW (1-888-576-5529). If you do not have an attorney and are not eligible for free legal assistance, you may obtain a referral to an attorney by calling one of the Lawyer Referral Services. A directory with contact information for local Legal Services Offices and Lawyer Referral Services is available in the Civil Division Management Office in the county listed above and online at http://www.njcourts.gov. Clerk of the Superior Court DATED: 03/17/2024 Name of Defendant to Be Served: Jonathan Vega Address of Defendant to Be Served: Jonathan Vega, 731 White House Pike, Hammonton, NJ 08037 Revised 11/17/2014, CN 10792-English (Appendix XII-A) ATL-L-000500-24 03/18/2024 ATL-L-000500-24 03/18/20242:00:00 2:00:00AM AM Pg 1 of 1 Trans TransID: ID:LCV2024695578 LCV2024695578 Civil Case Information Statement Case Details: ATLANTIC | Civil Part Docket# L-000500-24 Case Caption: TORRES ALLAN VS VEGA AUTO Case Type: EMPLOYMENT (OTHER THAN CEPA OR LAD) DETAILING, LLC Document Type: Complaint with Jury Demand Case Initiation Date: 03/18/2024 Jury Demand: YES - 12 JURORS Attorney Name: ANDREW IRA GLENN Is this a professional malpractice case? NO Firm Name: JAFFE GLENN LAW GROUP, PA Related cases pending: NO Address: 300 CARNEGIE CTR STE 150 If yes, list docket numbers: PRINCETON NJ 08540 Do you anticipate adding any parties (arising out of same Phone: 2016879977 transaction or occurrence)? NO Name of Party: PLAINTIFF : Torres, Allan Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): Unknown Are sexual abuse claims alleged by: Allan Torres? 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? YES If yes, is that relationship: Employer/Employee 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) 03/18/2024 /s/ ANDREW IRA GLENN Dated Signed