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MID-L-002640-24 05/02/2024 10:23:11AM Pglof2 Trans ID: LCV20241115140
ANGLIN REA CAHALANE & PIEPER, P.A.
PatrickH. Cahalane, Esq., ID #02152-1992
Attorney for Plaintiff(s)
1005 Eastpark Boulevard
Cranbury, New Jersey 08512
(609)409-0444 ToR ony
SUPERIOR COURT OF NEW JERSEY
KENNETH KEARSTAN, LAW DIVISION
Plaintiff(s) MIDDLESEX COUNTY
VS.
NAVNEET KAUR; Docket No.
UBER EATS, INC., UBER
TECHNOLOGIES, INC.; PORTIER, LLC;
TOUATTANE
JOHN/JANE DOE i-5
and/or ABC CORP. 1-5 (fictitious
names/entities) Civil Action
Defendant(s) COMPLAINT
Plaintiff, KENNETH KEARSTAN, residing at 39 Carlton Street South, Edison, Middlesex County,
State of New Jersey by way of Complaint against the above named defendants, says
1 On or about June 20, 2023, plaintiff, KENNETH KEARSTAN, was the owner and operator
of a certain motor vehicle travelling on New Brunswick Avenue, Woodbridge, Middlesex County, State of
New Jersey
2. At the time and place aforesaid, defendant(s), NAVNEET KAUR, and/or JOHN/JANE DOE
1 (fictitious names/entities), was the operator of a certain motor vehicle and was in the course of
employment or otherwise acting as an agent for the owner of the vehicle, NAVNEET KAUR, UBER EATS.
moe TINICY TOVINT/T nne 9. Rec corp
INU. UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE DOE 2-5 and/or ABC CORP. i-5
(fictitious names/entities). Defendant, NAVNEET KAUR and/or JOHN/JANE DOE 1, operated said motor
vehicle in a negligent and careless manner causing same to become involved in a collision with the motor
vehicle in which plaintiff, KENNETH KEARSTAN, was an owner and operator.
2
3 As a direct result of the carelessness and negligence or defendant(s), NAVINEEL KAUR;
UBER EATS, INC.; UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE
DOE 1-5 and/or ABC
CORP. 1-5 (fictitious names/entities). plaintiff, KENNETH KEARSTAN, was caused to suffer injuries to
head, back, limbs and body; was caused to suffer great pain and will in the future be caused to suffer great
MID-L-002640-24 05/02/2024 10:23:11AM Pg2of2 Trans ID: LCV20241115140
pain; was caused to incur medical expenses and will in the future be caused to incur medical expenses, was
caused to suffer serious, severe and permanent injuries as well as property damage, vehicle damage, loss of
use and diminished value.
WHERURORE TTT
WHEREFORE, plaintiff, KENNETH KEARSTAN, demands judgment against the defendant(s),
NAVNEET KAUR, UBER EATS, INC.; UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE
DOE 1-5 and/or ABC CORP. 1-5 (fictitious ni pensatory damages, interest and costs
of suit.
ILIN RED s x Nrm
iL && PIEPER,
pI P.A.
Attorney for fi{s
Patrick H. Cahalane, Esq.
JURY QEMAND
Pursuant to Rule 1:8-2(b), plaintiffs hereby and that the is herein be tried by a jury of six
16) be
(6) persons.
ANGLIN & PIEPER, P.A.
Attomey for aintiff(s)
By: Patrick H. halane, Esq.
CERTIFI TI
1 certify that to my knowledge the within action the o: actioi ending concerning the subject
occurrence or transaction.
ANGLIN RE:
Attorney fox Plain
ey
By: Patrick B Cahalam 5
\& PIEPER, P.A.
Sq.
DESIGNATION OX TRIAL CQUNSES
In accordance with R.4:25-4, Patrick H. Cah Esq. ereby designated as trial counsel for
plaintiff.
ANGLI Pl TEPER, P.A.
Aftorn:
ttomeyet for
for Pla:
Piat
By: Pattick H. Caha! Esq.
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MID-L-002640-24 05/02/2024 10:23:11AM Pglof2 Trans ID: LCV20241115140 ANGLIN REA CAHALANE & PIEPER, P.A. PatrickH. Cahalane, Esq., ID #02152-1992 Attorney for Plaintiff(s) 1005 Eastpark Boulevard Cranbury, New Jersey 08512 (609)409-0444 ToR ony SUPERIOR COURT OF NEW JERSEY KENNETH KEARSTAN, LAW DIVISION Plaintiff(s) MIDDLESEX COUNTY VS. NAVNEET KAUR; Docket No. UBER EATS, INC., UBER TECHNOLOGIES, INC.; PORTIER, LLC; TOUATTANE JOHN/JANE DOE i-5 and/or ABC CORP. 1-5 (fictitious names/entities) Civil Action Defendant(s) COMPLAINT Plaintiff, KENNETH KEARSTAN, residing at 39 Carlton Street South, Edison, Middlesex County, State of New Jersey by way of Complaint against the above named defendants, says 1 On or about June 20, 2023, plaintiff, KENNETH KEARSTAN, was the owner and operator of a certain motor vehicle travelling on New Brunswick Avenue, Woodbridge, Middlesex County, State of New Jersey 2. At the time and place aforesaid, defendant(s), NAVNEET KAUR, and/or JOHN/JANE DOE 1 (fictitious names/entities), was the operator of a certain motor vehicle and was in the course of employment or otherwise acting as an agent for the owner of the vehicle, NAVNEET KAUR, UBER EATS. moe TINICY TOVINT/T nne 9. Rec corp INU. UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE DOE 2-5 and/or ABC CORP. i-5 (fictitious names/entities). Defendant, NAVNEET KAUR and/or JOHN/JANE DOE 1, operated said motor vehicle in a negligent and careless manner causing same to become involved in a collision with the motor vehicle in which plaintiff, KENNETH KEARSTAN, was an owner and operator. 2 3 As a direct result of the carelessness and negligence or defendant(s), NAVINEEL KAUR; UBER EATS, INC.; UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE DOE 1-5 and/or ABC CORP. 1-5 (fictitious names/entities). plaintiff, KENNETH KEARSTAN, was caused to suffer injuries to head, back, limbs and body; was caused to suffer great pain and will in the future be caused to suffer great MID-L-002640-24 05/02/2024 10:23:11AM Pg2of2 Trans ID: LCV20241115140 pain; was caused to incur medical expenses and will in the future be caused to incur medical expenses, was caused to suffer serious, severe and permanent injuries as well as property damage, vehicle damage, loss of use and diminished value. WHERURORE TTT WHEREFORE, plaintiff, KENNETH KEARSTAN, demands judgment against the defendant(s), NAVNEET KAUR, UBER EATS, INC.; UBER TECHNOLOGIES, INC.; PORTIER, LLC; JOHN/JANE DOE 1-5 and/or ABC CORP. 1-5 (fictitious ni pensatory damages, interest and costs of suit. ILIN RED s x Nrm iL && PIEPER, pI P.A. Attorney for fi{s Patrick H. Cahalane, Esq. JURY QEMAND Pursuant to Rule 1:8-2(b), plaintiffs hereby and that the is herein be tried by a jury of six 16) be (6) persons. ANGLIN & PIEPER, P.A. Attomey for aintiff(s) By: Patrick H. halane, Esq. CERTIFI TI 1 certify that to my knowledge the within action the o: actioi ending concerning the subject occurrence or transaction. ANGLIN RE: Attorney fox Plain ey By: Patrick B Cahalam 5 \& PIEPER, P.A. Sq. DESIGNATION OX TRIAL CQUNSES In accordance with R.4:25-4, Patrick H. Cah Esq. ereby designated as trial counsel for plaintiff. ANGLI Pl TEPER, P.A. Aftorn: ttomeyet for for Pla: Piat By: Pattick H. Caha! Esq.