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MID-L-003514-24 06/14/2024 1:45:41 PM Pgiof5 Trans ID: LCV20241501226
John F. Kwasnik, Esq. - 005241993
Mezzacca & Kwasnik, LLC
980 Amboy Avenue, Suite 2
Edison, New Jersey 08837
PHONE: (732) 549-4600
FAX: (732) 549-8028
Attorneys for Plaintiff, Adel Tawfik
SUPERIOR COURT OF NEW JERSEY
ADEL TAWFIK, MIDDLESEX COUNTY-LAW DIVISION
Plaintiff,
DOCKET NO.:
Vs.
Civil Action
VICTORIN MYRQUET,
COMPLAINT
Defendants.
Plaintiff, Adel Tawfik, residing at 7 Latham Circle, Parlin, New Jersey, by way of complaint
against the Defendant states as follows:
Background of the Parties
1 Adel Tawfik (hereinafter referred to as “Tawfik”) is the owner of towing
company named AT Towing with a business address of 341 Colfax Street, Perth Amboy, New
Jersey.
2. Defendant, Victorin Myrquet, (hereinafter referred to as “Myrquet”) resides at 11
Legion Place, Woodbridge, New Jersey.
3 On or about June 18, 2022, Myrquet went to Tawfik’s tow yard where his vehicle
had been towed legally.
4. Myrquet failed to observe-due-care-and precaution and to maintain proper and
adequate control of the motor vehicle and failed to exercise reasonable care in the operation of
MID-L-003514-24 06/14/2024 1:45:41 PM Pg2of5 Trans ID: LCV20241501226
the motor vehicle under the circumstances then and there existing and in other respects not now
known to the Tawfik but which may become known before or at the time of trial.
5 As a direct and proximate result of the negligence and carelessness of Myrquet,
Tawfik suffered painful bodily injury, great physical pain and mental anguish, severe and
substantial emotional distress, and otherwise was hurt, injured, and caused to sustain losses.
6 All of the Tawfik’s losses were, are, and will be due to the carelessness and
negligence of the Myrquet without any negligence or want of due care on the Tawfik’s part
contributing to the harm done.
WHEREFORE, Plaintiff, Adel Tawfik, demands judgment against the Defendant, Victorin
Myrquet, for money damages, plus interest, attorneys’ fees, cost of suit and any other relief deemed
appropriate by the Court.
TRIAL DESIGNATION
In accordance with R. 4:25-4, John F. Kwasnik, Esq., is hereby designated as trial attorney
for the plaintiffs on the within matter.
URY DEMAND
Plaintiffs hereby demand a trial by jury in accordance with R. 1:8-2 and 4:35-1.
CERTIFICATION OF NO OTHER ACTION
Pursuant to Rule 4:5-1, itis hereby stated that the matter in controversy is not the subject of
any other action pending in any other Court or of a pending arbitration proceeding to the best of our
knowledge and belief. Also, to the best of our knowledge and belief, no other action or arbitration
proceeding is contemplated. Further, other than the parties set forth in this pleading, we know of no
other parties that could or should be joined in the above action. In addition, we recognize the
continuing obligation of each party to file and serve on all parties and the Court an amended
MID-L-003514-24 06/14/2024 1:45:41PM Pg3of5 Trans ID: LCV20241501226
certification if there is a change in the facts stated in this original certification.
DEMAND FOR DISCOVERY OF INSURANCE COVERAGE
Pursuant to Rule 4: 10-2(b), demand is made that defendant disclose to plaintiff's attorney
whether or not there are any insurance agreements or policies under which any person or firm
carrying on an insurance business may be liable to satisfy part or all of a judgment which may be
entered in this action, or indemnify or reimburse for payments made to satisfy part or all of the
judgment, and provide plaintiff's attorney with true copies of those insurance agreements or policies,
including, but not limited to, any and all declaration sheets.
DEMAND FOR PRODUCTION
Demand is hereby made upon you pursuant to Rule 4: 10-2 and 4: 18-1 for you to produce for
inspection and copying the Spevack L.aw Firm, 525 Green Street, Iselin, New Jersey, on the SOth
day following the service date of this notice, all of the documents and items listed on the atuched:
You are requested to respond to this Demand for Production in writing within the time requested
above pursuant to Rule 4: 18-1, and indicate in your response, on an item-by-item basis, the
following:
1 Any statements made by plaintiff in your possession, in either written form or oral
form, including tape recordings, videotapes, written statements, summaries of oral statements or any
other form.
2. Any records in your possession regarding a prior accident, injury, medical condition,
or lawsuit relating to plaintiff, regardless of whether you intend to use said documents as evidence at
trial.
3 Any records in your possession regarding a subsequent accident, injury, medical
condition, or lawsuit relating to plaintiff, regardless of whether you intend to use said documents as
MID-L-003514-24 06/14/2024 1:45:41PM Pg4of5 Trans ID: LCV20241501226
evidence at trial.
4. Names and addresses of all witnesses that you have identified, who have relevant
information about the subject matter of this litigation.
5 Copies of all statements from all witnesses identified in answer 4, either in video
taped, audio taped, or written form, or, if oral statements, a written summary of said statements,
including date, time and location of where statement made and to whom the statement was made.
6 A copy of the declaration page for all insurance policies in effect on the relevant dates
of this incident, providing insurance coverage for Defendant, including applicable policy limits.
7
Any evidence tending to impeach any expert witnesses named by Defendant as
potential witnesses in this matter, including court and/or deposition transcripts, records of
disciplinary proceedings, in either a public forum or private association/group forum, criminal
records, prior narrative reports or other records authored by those witnesses, or any other documents
tending to impeach the testimony of any expert witnesses named by Defendant.
8 Names, addresses and contact information of any expert witnesses identified by
defendant, including their curriculum vitae.
9 Any items of evidence which defendant intends to introduce as evidence at trial of
this matter.
10. Photographs, videotapes, maps, and other graphic documents depicting any of the
events forming the subject matter of this litigation.
IL. Any records of disciplinary actions, penalties, punishments, salary reductions or work
termination issued to defendant as a result of the motor vehicle accident.
12. Any statements made by Plaintiff in your possession, in either written form or oral
form, including tape recordings, videotapes, written statements, summaries of oral statements or any
MID-L-003514-24 06/14/2024 1:45:41 PM Pg5of5 Trans ID: LCV20241501226
other form.
Mezzacca & Kwasnik, LLC.
DATED: by / oY MARIO A. FERRARO
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MID-L-003514-24 06/14/2024 1:45:41 PM Pgiof5 Trans ID: LCV20241501226 John F. Kwasnik, Esq. - 005241993 Mezzacca & Kwasnik, LLC 980 Amboy Avenue, Suite 2 Edison, New Jersey 08837 PHONE: (732) 549-4600 FAX: (732) 549-8028 Attorneys for Plaintiff, Adel Tawfik SUPERIOR COURT OF NEW JERSEY ADEL TAWFIK, MIDDLESEX COUNTY-LAW DIVISION Plaintiff, DOCKET NO.: Vs. Civil Action VICTORIN MYRQUET, COMPLAINT Defendants. Plaintiff, Adel Tawfik, residing at 7 Latham Circle, Parlin, New Jersey, by way of complaint against the Defendant states as follows: Background of the Parties 1 Adel Tawfik (hereinafter referred to as “Tawfik”) is the owner of towing company named AT Towing with a business address of 341 Colfax Street, Perth Amboy, New Jersey. 2. Defendant, Victorin Myrquet, (hereinafter referred to as “Myrquet”) resides at 11 Legion Place, Woodbridge, New Jersey. 3 On or about June 18, 2022, Myrquet went to Tawfik’s tow yard where his vehicle had been towed legally. 4. Myrquet failed to observe-due-care-and precaution and to maintain proper and adequate control of the motor vehicle and failed to exercise reasonable care in the operation of MID-L-003514-24 06/14/2024 1:45:41 PM Pg2of5 Trans ID: LCV20241501226 the motor vehicle under the circumstances then and there existing and in other respects not now known to the Tawfik but which may become known before or at the time of trial. 5 As a direct and proximate result of the negligence and carelessness of Myrquet, Tawfik suffered painful bodily injury, great physical pain and mental anguish, severe and substantial emotional distress, and otherwise was hurt, injured, and caused to sustain losses. 6 All of the Tawfik’s losses were, are, and will be due to the carelessness and negligence of the Myrquet without any negligence or want of due care on the Tawfik’s part contributing to the harm done. WHEREFORE, Plaintiff, Adel Tawfik, demands judgment against the Defendant, Victorin Myrquet, for money damages, plus interest, attorneys’ fees, cost of suit and any other relief deemed appropriate by the Court. TRIAL DESIGNATION In accordance with R. 4:25-4, John F. Kwasnik, Esq., is hereby designated as trial attorney for the plaintiffs on the within matter. URY DEMAND Plaintiffs hereby demand a trial by jury in accordance with R. 1:8-2 and 4:35-1. CERTIFICATION OF NO OTHER ACTION Pursuant to Rule 4:5-1, itis hereby stated that the matter in controversy is not the subject of any other action pending in any other Court or of a pending arbitration proceeding to the best of our knowledge and belief. Also, to the best of our knowledge and belief, no other action or arbitration proceeding is contemplated. Further, other than the parties set forth in this pleading, we know of no other parties that could or should be joined in the above action. In addition, we recognize the continuing obligation of each party to file and serve on all parties and the Court an amended MID-L-003514-24 06/14/2024 1:45:41PM Pg3of5 Trans ID: LCV20241501226 certification if there is a change in the facts stated in this original certification. DEMAND FOR DISCOVERY OF INSURANCE COVERAGE Pursuant to Rule 4: 10-2(b), demand is made that defendant disclose to plaintiff's attorney whether or not there are any insurance agreements or policies under which any person or firm carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action, or indemnify or reimburse for payments made to satisfy part or all of the judgment, and provide plaintiff's attorney with true copies of those insurance agreements or policies, including, but not limited to, any and all declaration sheets. DEMAND FOR PRODUCTION Demand is hereby made upon you pursuant to Rule 4: 10-2 and 4: 18-1 for you to produce for inspection and copying the Spevack L.aw Firm, 525 Green Street, Iselin, New Jersey, on the SOth day following the service date of this notice, all of the documents and items listed on the atuched: You are requested to respond to this Demand for Production in writing within the time requested above pursuant to Rule 4: 18-1, and indicate in your response, on an item-by-item basis, the following: 1 Any statements made by plaintiff in your possession, in either written form or oral form, including tape recordings, videotapes, written statements, summaries of oral statements or any other form. 2. Any records in your possession regarding a prior accident, injury, medical condition, or lawsuit relating to plaintiff, regardless of whether you intend to use said documents as evidence at trial. 3 Any records in your possession regarding a subsequent accident, injury, medical condition, or lawsuit relating to plaintiff, regardless of whether you intend to use said documents as MID-L-003514-24 06/14/2024 1:45:41PM Pg4of5 Trans ID: LCV20241501226 evidence at trial. 4. Names and addresses of all witnesses that you have identified, who have relevant information about the subject matter of this litigation. 5 Copies of all statements from all witnesses identified in answer 4, either in video taped, audio taped, or written form, or, if oral statements, a written summary of said statements, including date, time and location of where statement made and to whom the statement was made. 6 A copy of the declaration page for all insurance policies in effect on the relevant dates of this incident, providing insurance coverage for Defendant, including applicable policy limits. 7 Any evidence tending to impeach any expert witnesses named by Defendant as potential witnesses in this matter, including court and/or deposition transcripts, records of disciplinary proceedings, in either a public forum or private association/group forum, criminal records, prior narrative reports or other records authored by those witnesses, or any other documents tending to impeach the testimony of any expert witnesses named by Defendant. 8 Names, addresses and contact information of any expert witnesses identified by defendant, including their curriculum vitae. 9 Any items of evidence which defendant intends to introduce as evidence at trial of this matter. 10. Photographs, videotapes, maps, and other graphic documents depicting any of the events forming the subject matter of this litigation. IL. Any records of disciplinary actions, penalties, punishments, salary reductions or work termination issued to defendant as a result of the motor vehicle accident. 12. Any statements made by Plaintiff in your possession, in either written form or oral form, including tape recordings, videotapes, written statements, summaries of oral statements or any MID-L-003514-24 06/14/2024 1:45:41 PM Pg5of5 Trans ID: LCV20241501226 other form. Mezzacca & Kwasnik, LLC. DATED: by / oY MARIO A. FERRARO