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MID-L-002498-24 04/25/2024 4:20:42 PM Pg 1 of 9 Trans ID: LCV20241062699
STATHIS & LEONARDIS LLC
Nicholas J. Leonardis Bar ID 009651992
32 South Main Street
Edison NJ 08837-3452
(732) 494-0600; Fax (732) 494-0206
File: 23-5431-NJL
Attorneys for Plaintiff
ALVARO ROJAS-ORDONEZ, an SUPERIOR COURT OF NEW JERSEY
individual, LAW DIVISION – MIDDLESEX COUNTY
DOCKET NO.:
Plaintiff,
v. Civil Action
JAMES V. GATTONE, JR., an individual; Complaint & Jury Demand
JAMES T. MARKEY HOME
REMODELING LLC, a business entity;
JOHN DOES 1-5, fictitious individuals; and,
ABC COS. 1-5, fictitious business entities,
Defendants.
Plaintiff, Alvaro Rojas-Ordonez, residing at 647 4th Street #A, Bridgewater, Somerset
County, New Jersey complaining of the above-named Defendants, says:
VENUE: Venue in this matter is properly brought in Middlesex County, as Defendant, James
T. Markey Home Remodeling, LLC is a limited liability company doing business
throughout the State of New Jersey and all its counties as confirmed by it’s website
in which it recites: “Serving Central New Jersey…..Middlesex,” and on to identify
under cities served “Avenel, Carteret, East Brunswick, Kendall Park, East Brunswick,
Iselin, Middlesex, Monmouth Junction, New Brunswick, North Brunswick,
Piscataway and Dunellen.
FIRST COUNT
1. On or about March 22, 2023, Plaintiff, Alvaro Rojas-Ordonez, was the operator of
a motor vehicle owned by Alvaro J. Rojas on State Highway 28 at or near its intersection with
US Highway 202-206, in the Township of Bridgewater, County of Somerset, and State of New
Jersey.
2. At the time and place aforesaid, the Defendant, James T. Markey Home
MID-L-002498-24 04/25/2024 4:20:42 PM Pg 2 of 9 Trans ID: LCV20241062699
Remodeling LLC was the owner of a motor vehicle being operated Defendant, James V.
Gattone, Jr., as its agent, servant and/or also on State Highway 28, at or near its intersection with
US Highway 202-206 in the Township of Bridgewater, County of Somerset and State of New
Jersey.
3. At the time and place aforesaid, Plaintiff brought his vehicle to a complete stop
at a yield sign, waiting to merge onto US Highway 202-206.
4. At the time and place aforesaid, Defendant, James V. Gattone, Jr., individually
and/or as agent, servant and/or employee of Defendant, James T. Markey Home Remodeling
LLC and Defendant, James T. Markey Home Remodeling LLC , did own, operate, control and
maintain their motor vehicle in careless, reckless and negligent such that Defendant, James V.
Gattone, Jr. did cause the motor vehicle he was operating to collide directly into the rear of
Plaintiff’s stopped vehicle.
5. As a direct and proximate result of the aforesaid carelessness and negligence of the
Defendants, and the ensuing collision, Plaintiff, Alvaro Rojas-Ordonez, severely and permanently
injured, suffered great pain and mental anguish, was and will in the future require medical care
and attention due to the permanent nature of the injuries sustained, was and will in the future be
compelled to expend large sums of money for said medical care and attention in an attempt to cure
himself, and was and will in the future be prevented from engaging in his normal pursuits and daily
activities.
WHEREFORE, Plaintiff, Alvaro Rojas-Ordonez, demands judgment against the
Defendants, James V. Gattone, Jr. and James T. Markey Home Remodeling LLC, jointly and
MID-L-002498-24 04/25/2024 4:20:42 PM Pg 3 of 9 Trans ID: LCV20241062699
severally, for:
a. Compensatory damages;
b. Attorneys fees;
c. Interest and costs of suit; and,
d. For such other relief as the Court may deem appropriate.
SECOND COUNT
5. Plaintiff, Alvaro Rojas-Ordonez, repeats and reiterates each of the allegations of
the First Count, as though fully set forth at length herein.
6. John Does 1-5 and ABC Cos. 1-5, represent fictitiously named individuals
and/or business entities who owned, operated, controlled, repaired and/or maintained, any
vehicle, or in any way may have contributed or caused the accident herein not identified herein.
7. To date, the names of these individuals and/or business entities are unknown to
Plaintiff. Plaintiff reserves his right to amend the within Complaint to incorporate the name of
such individuals and/or entities in the event their names are identified and/or liability of same are
identified during the normal course of discovery.
WHEREFORE, Plaintiff, Alvaro Rojas-Ordonez, does hereby demand judgment against
the Defendants, John Does 1-5 and/or ABC Cos 1-5, jointly and severally, for:
a. Compensatory damages;
b. Attorney’s fees;
c. Interest and costs of suit; and,
d. For such other relief as the Court may deem appropriate.
JURY DEMAND
Plaintiff hereby demands a trial by jury of six (6) on all issues so triable.
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DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4: 25-4, Nicholas J. Leonardis, Esq. is hereby designated as trial counsel.
DEMAND FOR ANSWERS TO UNIFORM AND SUPPLEMENTAL
INTERROGATORIES
Pursuant to Rule 4:17-1, Plaintiff hereby demands Answers to Uniform Interrogatories
Form C, C (1) and the Supplemental Interrogatories included herein, within sixty (60) days of the
filing of defendants’ Answer to this Complaint.
DEMAND FOR NOTICE TO PRODUCE
Pursuant to Rule 4:18-1, Plaintiff hereby demands documents in response to the Notice
to Produce included herein within fifty (50) days of the filing of defendant’s Answer to this
Complaint.
NOTICE TO PRESERVE ELECTRONICALLY STORED INFORMATION
PLEASE TAKE NOTICE that Plaintiff, during the course of this lawsuit, will
request from the Defendant(s) the discovery of electronically stored information (ESI). ESI may
be present on home and business computers, cell ‘phones, hard drives, floppy discs, DVDs,
USBs and CDs, flash memory, voice mail systems, e-mail programs, PDAs, tablets, web pages,
server backup tapes, etc. Defendant(s) should not destroy any such materials that may be relevant
to this case. Defendant(s) should take steps to preserve all information related in any way to
Plaintiff and/or this lawsuit. Storage and retention policies for all systems should be reviewed,
and any automatic purges, deletions, or write-overs must be stopped until this litigation is
concluded.
Failure to ensure that all currently existing ESI is maintained and protected may
subject the Defendant(s) to sanctions and adverse inferences for spoliation of evidence. Counsel
for the respective parties can discuss how ESI will be exchanged.
MID-L-002498-24 04/25/2024 4:20:42 PM Pg 5 of 9 Trans ID: LCV20241062699
NOTICE RELATING TO SERVICE OF DISCOVERY
If any defendants intend to serve supplemental discovery, please serve same via email upon
lbean@stathisleonardis.com or jjimenez@stathisleonardis.com.
STATHIS & LEONARDIS LLC
Attorneys for Plaintiff
By: ______________________________
NICHOLAS J. LEONARDIS
DATED: April 26, 2024
CERTIFICATION
It is hereby certified that to the best, present knowledge of Counsel for Plaintiff, that the
matter in controversy which is the subject of this litigation involving the named parties hereto, is
not the subject matter of controversy in any other pending litigation or arbitration proceeding, and
to the best of my knowledge and belief, no other action or arbitration proceeding is contemplated.
To the best of my knowledge, information and belief, there are no other parties to be
joined in this action, and I recognize my continuing obligation to file and serve on all
parties and the Court an amended certification if there is a change in the facts herein.
I further 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).
I certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements made by me are willfully false, I am subject to punishment.
___________________________________
NICHOLAS J. LEONARDIS
DATED: April 25, 2024
MID-L-002498-24 04/25/2024 4:20:42 PM Pg 6 of 9 Trans ID: LCV20241062699
SUPPLEMENTAL INTERROGATORIES
S1. State the names and addresses of any and all proposed expert witnesses; their field of
expertise; and the subject matter on which each expert is expected to testify. Annex a true copy of
any and all proposed experts written reports and/or transcription of any oral report.
S2. State the substance of any statement you gave to any police officer as to the manner of the
happening of the subject accident.
S3. State the speed of the vehicle you were in when the operator first saw the vehicle with
which it collided.
S4. State the speed of the vehicle with which your vehicle collided at the time you first saw
said other vehicle.
S5. State as accurately as you can the speed of the vehicle you were in at the time of the impact
and the speed of the vehicle with which your vehicle collided at the time of impact.
S6. If any driver involved in the subject accident pleaded “guilty” to a charge under the motor
vehicle laws for a violation that occurred at the time of the happening of the accident or
immediately prior thereto, state the charge made, the name of the person who pleaded “guilty” to
said charge, the municipality where said plea was taken, and the date said plea was entered.
S7. State the street address and name of the exact place where you had been on the last occasion
before you entered the car before the happening of the accident and the exact street address and
name of the place where you next intended to drive to at the time of the happening of the subject
accident.
S8. If the operator of any vehicle consumed any drugs; medication or alcoholic beverages
within a 12 hour period immediately preceding the happening of the subject accident, state the
name of the person who consumed such medication, drug or alcoholic beverage, the amount and
kind of beverage drug or medication consumed, and the location where each of said items was
consumed and the name and address of each person who was present at the time said consumption
took place.
S9. If any person named in the answers to Interrogatories was ever convicted of a crime, set forth
the name of each person who was convicted of a crime, the name of the crime or crime, the state
or country where such conviction took place and the date of each said conviction took place and
the date of each said conviction.
MID-L-002498-24 04/25/2024 4:20:42 PM Pg 7 of 9 Trans ID: LCV20241062699
S10. If you claim that the plaintiff sustained prior or subsequent injuries in prior or
subsequent accidents or that plaintiff had a prior physical or mental condition, state the nature of
the prior injury or condition, its date of occurrence, whether any claim or suit was associated with
same, date of the disposition of any such prior or subsequent claim, the court and docket number
associated with such claim, and the name and address of attorneys involved with any prior or
subsequent claim.
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NOTICE TO PRODUCE
1. The amounts of any and all insurance coverage covering the defendant, or any
resident relative at the time of this accident, including but not limited to, primary insurance
policies, secondary insurance policies and/or umbrella insurance policies. For each such policy of
insurance, supply a copy of the declaration page therefrom.
2. Copies of any and all documentation or reports, including but not limited to, police
reports, accident reports and/or incident reports concerning the happening of the incident in
question or any subsequent investigation of same.
3. Copies or duplicates of any and all photographs, motion pictures, videotapes, films,
drawings, diagrams, sketches or other reproductions, descriptions or accounts concerning the
individuals involved in the incident in question, the property damage sustained, the accident scene
or anything else relevant to the incident in question.
4. Copies of any and all signed or unsigned statement, documents, communications
and/or transmissions, whether in writing, made orally or otherwise recorded by any mechanical or
electronic means, made by any party to this action, any witness, or any other individual, business,
corporation, investigative authority or other entity concerning anything relevant to the incident in
question.
5. Copies of any and all documentation, including but not limited to, any contracts for
service and/or repair orders for recent service and/or maintenance work performed on the vehicle
involved in this accident and any other party.
6. Copies of any and all documentation concerning any lease agreements concerning
the vehicle involved in this accident.
7. Copies of any and all discovery received from any other parties to the action in
question.
8. Copies of any and all reports on the plaintiff received by the defendants, or any
other party to this suit, from either the Central Index Bureau (C.I.B.) or from any other source.
9. Copies of any and all reports and/or other investigations performed by any other
investigative authority.
10. Copies of any and all medical information and/or documentation concerning the
plaintiff in this matter whether it concerns any medical condition or treatment which took place
before, during or after the time of the incident in question.
11. Copies of any and all records of any type Subpoenaed by the defendant or
received from any other source concerning the plaintiff or the incident in question.
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12. Any and all video surveillance capturing defendant(s) activities on the day of the
accident.
13. All incident, or accident reports prepared by or on behalf the defendant
company(ies), or its driver.
14. The full name, address, and employment file for the defendant company(ies)
driver who was operating the vehicle at the time of the accident.
15 Copy of the property damage claim file for this claim, including all photographs,
estimates, statements, reports, and repair records.
16. All GPS, speed, tracking data, and, EZ Pass information as recorded by defendant
company(ies) vehicle.
17. All photographs and video equipment surveillance taken from within defendants’
vehicle capturing and recording the happening of the incident/accident which is the subject
matter of this suit and/or its aftermath.
18. At least twenty-five (25) days prior to any and all independent medical
examinations of Plaintiff scheduled by defense or on behalf of the defense by his/her attorney or
carrier, provide to Plaintiff’s counsel any and all intake forms that said examining doctor will
require. Plaintiff reserves the right to audiotape the complete medical examination, including
questioning by the doctor and/or his staff. Plaintiff further reserves the right to have a third person,
as a representative of the Plaintiff, attend the medical examination, and record the medical
examination (by audio or note taking), but will, in no way, interfere, or in any way participate in
the medical examination. Failure to advise counsel of any objection thereto, will result in a motion
to bar testify filed with the Court.
19. Within thirty (30) days of Plaintiff’s defense independent medical examination,
produce a copy of all notes taken by the independent medical examining doctor and his staff if the
independent medical examining doctor, or his staff takes notes. Destruction of the notes will
constitute spoliation of evidence. All available remedies for spoliation of evidence by the
examining doctor, will be pursued by the Plaintiff.
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MID-L-002498-24 04/25/2024 4:20:42 PM Pg 1 of 9 Trans ID: LCV20241062699 STATHIS & LEONARDIS LLC Nicholas J. Leonardis Bar ID 009651992 32 South Main Street Edison NJ 08837-3452 (732) 494-0600; Fax (732) 494-0206 File: 23-5431-NJL Attorneys for Plaintiff ALVARO ROJAS-ORDONEZ, an SUPERIOR COURT OF NEW JERSEY individual, LAW DIVISION – MIDDLESEX COUNTY DOCKET NO.: Plaintiff, v. Civil Action JAMES V. GATTONE, JR., an individual; Complaint & Jury Demand JAMES T. MARKEY HOME REMODELING LLC, a business entity; JOHN DOES 1-5, fictitious individuals; and, ABC COS. 1-5, fictitious business entities, Defendants. Plaintiff, Alvaro Rojas-Ordonez, residing at 647 4th Street #A, Bridgewater, Somerset County, New Jersey complaining of the above-named Defendants, says: VENUE: Venue in this matter is properly brought in Middlesex County, as Defendant, James T. Markey Home Remodeling, LLC is a limited liability company doing business throughout the State of New Jersey and all its counties as confirmed by it’s website in which it recites: “Serving Central New Jersey…..Middlesex,” and on to identify under cities served “Avenel, Carteret, East Brunswick, Kendall Park, East Brunswick, Iselin, Middlesex, Monmouth Junction, New Brunswick, North Brunswick, Piscataway and Dunellen. FIRST COUNT 1. On or about March 22, 2023, Plaintiff, Alvaro Rojas-Ordonez, was the operator of a motor vehicle owned by Alvaro J. Rojas on State Highway 28 at or near its intersection with US Highway 202-206, in the Township of Bridgewater, County of Somerset, and State of New Jersey. 2. At the time and place aforesaid, the Defendant, James T. Markey Home MID-L-002498-24 04/25/2024 4:20:42 PM Pg 2 of 9 Trans ID: LCV20241062699 Remodeling LLC was the owner of a motor vehicle being operated Defendant, James V. Gattone, Jr., as its agent, servant and/or also on State Highway 28, at or near its intersection with US Highway 202-206 in the Township of Bridgewater, County of Somerset and State of New Jersey. 3. At the time and place aforesaid, Plaintiff brought his vehicle to a complete stop at a yield sign, waiting to merge onto US Highway 202-206. 4. At the time and place aforesaid, Defendant, James V. Gattone, Jr., individually and/or as agent, servant and/or employee of Defendant, James T. Markey Home Remodeling LLC and Defendant, James T. Markey Home Remodeling LLC , did own, operate, control and maintain their motor vehicle in careless, reckless and negligent such that Defendant, James V. Gattone, Jr. did cause the motor vehicle he was operating to collide directly into the rear of Plaintiff’s stopped vehicle. 5. As a direct and proximate result of the aforesaid carelessness and negligence of the Defendants, and the ensuing collision, Plaintiff, Alvaro Rojas-Ordonez, severely and permanently injured, suffered great pain and mental anguish, was and will in the future require medical care and attention due to the permanent nature of the injuries sustained, was and will in the future be compelled to expend large sums of money for said medical care and attention in an attempt to cure himself, and was and will in the future be prevented from engaging in his normal pursuits and daily activities. WHEREFORE, Plaintiff, Alvaro Rojas-Ordonez, demands judgment against the Defendants, James V. Gattone, Jr. and James T. Markey Home Remodeling LLC, jointly and MID-L-002498-24 04/25/2024 4:20:42 PM Pg 3 of 9 Trans ID: LCV20241062699 severally, for: a. Compensatory damages; b. Attorneys fees; c. Interest and costs of suit; and, d. For such other relief as the Court may deem appropriate. SECOND COUNT 5. Plaintiff, Alvaro Rojas-Ordonez, repeats and reiterates each of the allegations of the First Count, as though fully set forth at length herein. 6. John Does 1-5 and ABC Cos. 1-5, represent fictitiously named individuals and/or business entities who owned, operated, controlled, repaired and/or maintained, any vehicle, or in any way may have contributed or caused the accident herein not identified herein. 7. To date, the names of these individuals and/or business entities are unknown to Plaintiff. Plaintiff reserves his right to amend the within Complaint to incorporate the name of such individuals and/or entities in the event their names are identified and/or liability of same are identified during the normal course of discovery. WHEREFORE, Plaintiff, Alvaro Rojas-Ordonez, does hereby demand judgment against the Defendants, John Does 1-5 and/or ABC Cos 1-5, jointly and severally, for: a. Compensatory damages; b. Attorney’s fees; c. Interest and costs of suit; and, d. For such other relief as the Court may deem appropriate. JURY DEMAND Plaintiff hereby demands a trial by jury of six (6) on all issues so triable. MID-L-002498-24 04/25/2024 4:20:42 PM Pg 4 of 9 Trans ID: LCV20241062699 DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4: 25-4, Nicholas J. Leonardis, Esq. is hereby designated as trial counsel. DEMAND FOR ANSWERS TO UNIFORM AND SUPPLEMENTAL INTERROGATORIES Pursuant to Rule 4:17-1, Plaintiff hereby demands Answers to Uniform Interrogatories Form C, C (1) and the Supplemental Interrogatories included herein, within sixty (60) days of the filing of defendants’ Answer to this Complaint. DEMAND FOR NOTICE TO PRODUCE Pursuant to Rule 4:18-1, Plaintiff hereby demands documents in response to the Notice to Produce included herein within fifty (50) days of the filing of defendant’s Answer to this Complaint. NOTICE TO PRESERVE ELECTRONICALLY STORED INFORMATION PLEASE TAKE NOTICE that Plaintiff, during the course of this lawsuit, will request from the Defendant(s) the discovery of electronically stored information (ESI). ESI may be present on home and business computers, cell ‘phones, hard drives, floppy discs, DVDs, USBs and CDs, flash memory, voice mail systems, e-mail programs, PDAs, tablets, web pages, server backup tapes, etc. Defendant(s) should not destroy any such materials that may be relevant to this case. Defendant(s) should take steps to preserve all information related in any way to Plaintiff and/or this lawsuit. Storage and retention policies for all systems should be reviewed, and any automatic purges, deletions, or write-overs must be stopped until this litigation is concluded. Failure to ensure that all currently existing ESI is maintained and protected may subject the Defendant(s) to sanctions and adverse inferences for spoliation of evidence. Counsel for the respective parties can discuss how ESI will be exchanged. MID-L-002498-24 04/25/2024 4:20:42 PM Pg 5 of 9 Trans ID: LCV20241062699 NOTICE RELATING TO SERVICE OF DISCOVERY If any defendants intend to serve supplemental discovery, please serve same via email upon lbean@stathisleonardis.com or jjimenez@stathisleonardis.com. STATHIS & LEONARDIS LLC Attorneys for Plaintiff By: ______________________________ NICHOLAS J. LEONARDIS DATED: April 26, 2024 CERTIFICATION It is hereby certified that to the best, present knowledge of Counsel for Plaintiff, that the matter in controversy which is the subject of this litigation involving the named parties hereto, is not the subject matter of controversy in any other pending litigation or arbitration proceeding, and to the best of my knowledge and belief, no other action or arbitration proceeding is contemplated. To the best of my knowledge, information and belief, there are no other parties to be joined in this action, and I recognize my continuing obligation to file and serve on all parties and the Court an amended certification if there is a change in the facts herein. I further 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). I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. ___________________________________ NICHOLAS J. LEONARDIS DATED: April 25, 2024 MID-L-002498-24 04/25/2024 4:20:42 PM Pg 6 of 9 Trans ID: LCV20241062699 SUPPLEMENTAL INTERROGATORIES S1. State the names and addresses of any and all proposed expert witnesses; their field of expertise; and the subject matter on which each expert is expected to testify. Annex a true copy of any and all proposed experts written reports and/or transcription of any oral report. S2. State the substance of any statement you gave to any police officer as to the manner of the happening of the subject accident. S3. State the speed of the vehicle you were in when the operator first saw the vehicle with which it collided. S4. State the speed of the vehicle with which your vehicle collided at the time you first saw said other vehicle. S5. State as accurately as you can the speed of the vehicle you were in at the time of the impact and the speed of the vehicle with which your vehicle collided at the time of impact. S6. If any driver involved in the subject accident pleaded “guilty” to a charge under the motor vehicle laws for a violation that occurred at the time of the happening of the accident or immediately prior thereto, state the charge made, the name of the person who pleaded “guilty” to said charge, the municipality where said plea was taken, and the date said plea was entered. S7. State the street address and name of the exact place where you had been on the last occasion before you entered the car before the happening of the accident and the exact street address and name of the place where you next intended to drive to at the time of the happening of the subject accident. S8. If the operator of any vehicle consumed any drugs; medication or alcoholic beverages within a 12 hour period immediately preceding the happening of the subject accident, state the name of the person who consumed such medication, drug or alcoholic beverage, the amount and kind of beverage drug or medication consumed, and the location where each of said items was consumed and the name and address of each person who was present at the time said consumption took place. S9. If any person named in the answers to Interrogatories was ever convicted of a crime, set forth the name of each person who was convicted of a crime, the name of the crime or crime, the state or country where such conviction took place and the date of each said conviction took place and the date of each said conviction. MID-L-002498-24 04/25/2024 4:20:42 PM Pg 7 of 9 Trans ID: LCV20241062699 S10. If you claim that the plaintiff sustained prior or subsequent injuries in prior or subsequent accidents or that plaintiff had a prior physical or mental condition, state the nature of the prior injury or condition, its date of occurrence, whether any claim or suit was associated with same, date of the disposition of any such prior or subsequent claim, the court and docket number associated with such claim, and the name and address of attorneys involved with any prior or subsequent claim. MID-L-002498-24 04/25/2024 4:20:42 PM Pg 8 of 9 Trans ID: LCV20241062699 NOTICE TO PRODUCE 1. The amounts of any and all insurance coverage covering the defendant, or any resident relative at the time of this accident, including but not limited to, primary insurance policies, secondary insurance policies and/or umbrella insurance policies. For each such policy of insurance, supply a copy of the declaration page therefrom. 2. Copies of any and all documentation or reports, including but not limited to, police reports, accident reports and/or incident reports concerning the happening of the incident in question or any subsequent investigation of same. 3. Copies or duplicates of any and all photographs, motion pictures, videotapes, films, drawings, diagrams, sketches or other reproductions, descriptions or accounts concerning the individuals involved in the incident in question, the property damage sustained, the accident scene or anything else relevant to the incident in question. 4. Copies of any and all signed or unsigned statement, documents, communications and/or transmissions, whether in writing, made orally or otherwise recorded by any mechanical or electronic means, made by any party to this action, any witness, or any other individual, business, corporation, investigative authority or other entity concerning anything relevant to the incident in question. 5. Copies of any and all documentation, including but not limited to, any contracts for service and/or repair orders for recent service and/or maintenance work performed on the vehicle involved in this accident and any other party. 6. Copies of any and all documentation concerning any lease agreements concerning the vehicle involved in this accident. 7. Copies of any and all discovery received from any other parties to the action in question. 8. Copies of any and all reports on the plaintiff received by the defendants, or any other party to this suit, from either the Central Index Bureau (C.I.B.) or from any other source. 9. Copies of any and all reports and/or other investigations performed by any other investigative authority. 10. Copies of any and all medical information and/or documentation concerning the plaintiff in this matter whether it concerns any medical condition or treatment which took place before, during or after the time of the incident in question. 11. Copies of any and all records of any type Subpoenaed by the defendant or received from any other source concerning the plaintiff or the incident in question. MID-L-002498-24 04/25/2024 4:20:42 PM Pg 9 of 9 Trans ID: LCV20241062699 12. Any and all video surveillance capturing defendant(s) activities on the day of the accident. 13. All incident, or accident reports prepared by or on behalf the defendant company(ies), or its driver. 14. The full name, address, and employment file for the defendant company(ies) driver who was operating the vehicle at the time of the accident. 15 Copy of the property damage claim file for this claim, including all photographs, estimates, statements, reports, and repair records. 16. All GPS, speed, tracking data, and, EZ Pass information as recorded by defendant company(ies) vehicle. 17. All photographs and video equipment surveillance taken from within defendants’ vehicle capturing and recording the happening of the incident/accident which is the subject matter of this suit and/or its aftermath. 18. At least twenty-five (25) days prior to any and all independent medical examinations of Plaintiff scheduled by defense or on behalf of the defense by his/her attorney or carrier, provide to Plaintiff’s counsel any and all intake forms that said examining doctor will require. Plaintiff reserves the right to audiotape the complete medical examination, including questioning by the doctor and/or his staff. Plaintiff further reserves the right to have a third person, as a representative of the Plaintiff, attend the medical examination, and record the medical examination (by audio or note taking), but will, in no way, interfere, or in any way participate in the medical examination. Failure to advise counsel of any objection thereto, will result in a motion to bar testify filed with the Court. 19. Within thirty (30) days of Plaintiff’s defense independent medical examination, produce a copy of all notes taken by the independent medical examining doctor and his staff if the independent medical examining doctor, or his staff takes notes. Destruction of the notes will constitute spoliation of evidence. All available remedies for spoliation of evidence by the examining doctor, will be pursued by the Plaintiff.