Motion for Case Management in Pennrose Llc Vs Apc Associates Llc| Trellis.Law

On May 30, 2018 a Answer was filed involving a dispute between Pennrose Llc, and Andre Oliveriera, Annette L Smith, Aparecida S Coutinho, Apc Associates Llc, Carl Muller, Carol L Radomski, Carol Muller, Chakrya K Molinoff, Charles Furlong, Christine E Herb, Christine Greatrex, Daniel Hanks, Daryl F Tonia, David Hercock, Diane Speer, Diego Castellanos, Doris G Blyler, Edward Mulka, Elizabeth Falco, Erika Gore, Eugene M Flacche, Eva Hanks, George C Greatrex Jr, George Freudenberg, Giovanna Ferriera, Hoover Quintero Garcia, Hui Y Shih, James E Weist, Jeffrey B Canfield, Jeffrey D Herb, Jeffrey L Molinoff, Joanne K Welch, John M Pfrommer, John S Radomski, Jose A Coutinho, Joseph Cavalieri, Karen Woznica, Katherine O Schimmel, Keenan Builders Llc, Lee H Schimmel, Margo Furlong, Marie E Kern, Ming T Shih, Muir A Mcmath, Paulette Smith, Rebecca Castellanos, Recon Investment Group Llc, Richard J Smith, Robert Gore, Robert Woznica, Ronnie M Tarchichi, Roseanne M Canfield, Russell Smith, Scott G Kern, Sigmund Tonia, Susan M Stevens, Syeda F Ahmed, Syed M Ahmed, Theodore J Speer Jr, Thomas B Mitchell, Umur Selek, Vito Brasile, Warren G Blyler, Wongsduan Mulka, for Mt. Laurel in the District Court of Burlington County.

Preview
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ATTACHED
cAfH ACCOUIiTT

PDPAOA o j. ,, .::r..
Sigmund Tonia PrYorL-5-lle;ll- i:
Daryl Fox-Tonia
l2 Meadorv
Moorestown,
Drive
NJ 08057
A.lCUa--I}le--
orslarr-fLESsl.l-
?;r3trAI IJ Attl0:3\
Pro Se Third-Party
rilr-ilvii
IN THE MATTER OF THE APPLICATION SUPERIOR COUT OF NEW JERSEY
OF THE TOWNSHIP OF MOORESTOWN, BTJRLINGTON COUNTY
BURLINGTON COUNTY, I-AW DIVISON

PENNROSE. LLC, DOCKETNO. L* 1604-15

Third-Party Plaintiff, Civil Action

Vs. ANSWER AND SEPARATE
DEFENSES TO FIRST AMENDED
APC ASSOCIATES, LLC, ET ALS. ANSWER AND THIRD-PARTY
COMPLAINT
Third-Party Defendants

ANSWf,,R AND SEPARATE DEFf,NSES

Third-Party Defendants, Sigmund Tonia (improperly pled as Tonia J. Signund) and

Daryl Fox-Tonia (improperly pled as Daryl T. Sigmund) files theirAnswer with Separate

Defenses to Third-Party Plaintiff, Pennrose, LLC's First Amended Answer and Third-Party

Complaint, and in support thereof states as follows:

THIRD.PARTY COMPLAINT

Introduction

t. 1'hird-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintills

First Amended Arswer and Third-Party Complaint.

2. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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The Parties

3. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

4. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

5. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

6. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

7. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

8. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

9. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiifs

First Amended Answer and Third-Party Complainl.

10. Third-Party Defendants deny lhe allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

I l. Third-Pany Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

12. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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13. Third-Party Defendants deny the allegations in this paragraph of Thi rd-Party Plaintiffs

First Amended Answer and Third-Party Complaint. By way of further answer, Sigmund Tonia

and Daryl Fox-Tonia own the real property located at and commonly known as l2 Meadow

Drive, Moorestown, New Jersey 08057.

14, Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Pa(y Complaint.

15. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plainliffs

First Amended Answer and Third-Party Complaint.

16. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintifls

First Amended Answer and Third-Party Complaint.

17. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

18. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

19. Third-Party Defendants deny lhe allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

20. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

21. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintifls

First Amended Answer and Third-Party Complaint.

22. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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23. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

24. Third-Party Defendants deny the allegations in this paragraph of Third-Parry Plaintiffs

First Amended Answer and Third-Party Complaint.

25. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

26. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

27. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

28. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

29. Third-Party Delendanls deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

30. Third-Party Defendanls deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Partv Complaint.

31. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

32. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plainti{fs

First Amended Answer and Third-Party Complaint.

33. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plainliffs

First Amended Answer and Third-Party Complaint.
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34. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

35- Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

36. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

37. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

38. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

39. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

40. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

41. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

42. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

43. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

44 Third-Party Det'endants deny the allegations in this paragraph of Third-Party Plaintif s

First Amended Answer and Third-Party Complaint.
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45. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintifls

First Amended Answer and Third-Party Complaint.

46 Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

Factual Background

A. History of the Property and the R$trictive Covenant

47. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complainl.

48. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

49. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

50. Third-Party Defendants deny the allegations in this paragraph ofThird-Parf Ptaintiffs

Firsl Amended Answer and Third-Party Complaint.

5 l. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

52. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

B, Pennrose's Intent to Develop the Property for Affordable Housing

53. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

54. Third-Party Defendants deny the allegations in this paragraph of Third-Party Ptaintiffs

First Amended Answer and Third-Party Complaint.
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55. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

56. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

57. Third-Party Defendants deny the allegations in this paragraph ofThird-Party PlaintifFs

First Amended Answer and Third-Party Complaint.

58. Third-Party Defendants deny the allegations in this paragraph ofThird-Parg Plaintiffs

First Amended Answer and Third-Party Complaint.

59. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

60. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Pa(y Complaint.

61. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

COUNTONE

(Invalidation of Restrictive Covenant - Mount Laurel Doctrine and Public Policy)

62. Denied. This is a pragraph of incorporation which requires no response.

By way of further response, Third-Party Defendants hereby incorporates by reference all ofthe

preceding paragraphs as though the same were herein set fo(h at lenglh To the exlent a

response is required, the allegations are denied.

63. Third-Party Defendants deny the allegations.in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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64- Third-Party Defendants deny the allegations in this paragraph ofThird-Party PlaintifFs

First Amended Answer and Third-Party Complaint.

65. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plainti{fs

First Amended Answer and Third-Party Complaint.

66. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

67. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

WHEREFORE, Third-Party Defendants, Sigmund Tonia and Daryl Fox-Tonia demands

judgment against Third-Party Plaintiff, Pennrose, LLC, together wrth reasonable attomey's fees,

legal expenses, costs ofsuit and such other reliefas the Cout deemsjust, equitable and proper.

COUNT TWO

(Invalidation of Restrictive Covenrnt - Common Law)

68. Denied. This is a paragraph of incorporation which requires no response.

By way of further response, Third-Party Defendants hereby incorporates by reference all ofthe

preceding paragraphs as though the sarne were herein set forth at lengrh. To the extent a

response is required, the allegations are denied.

69. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintifls

First Amended Answer and Third-Party Complaint.

70. Third-Parry Defendants deny the allegations in this paragraph ofThird-Party Plainrifrs

First Amended Answer and Third-Party Complaint.

Third-Party
7',I. Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Arswer and Third-Party Complaint'
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72. Thkd-Party Detendants deny the allegations in this paragraph ofThird-Party Plaintifls

First Amended Answer and Third-Party Complaint.

73. Third-Pany Delendants deny the allegations in this paragraph ofThird-Parry Plaintifs
First Amended Answer and Third-Party Complaint.

74. Third-Party Defendants deny the allegations in this paragaph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

75. Thrrd-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

WHERf,FORE, Third-Party Defendanls, Sigrnund Tonia and Daryl Fox-Tonia demands

judgment against Third-Pa(y Plaintiff, Penrrose, LLC, together with reasonable attorney's fees,

legal expenses, costs ofsuit and such other reliefas the Court deemsjust, equitable and proper.

COUNTTHREE

(Invalidation of Restrictive Covetrant - Invalid Neighborhood Scheme)

76. Denied. This is a paragraph ol incorporation which requires no response.

By way of further response, Third-Party Defendants hereby incorporates by referenc€ all ofthe

preceding paragraphs as though the same were herein set forth at tength. To the extent a

response is required, the allegations are denied.

77. Third-Party Defendants deny the allegations in this paragraph of Third-Party PlaintifPs

First Amended Answer and Third-Party Complaint.

78. Third-Party Defendants deny the allegations in this paragraph of Third-Party PlaintifFs

First Amended Answer and Third-Party Complaint.

79. Third-Parry Defendanls deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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80. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintifls

First Amended Answer and Third-Party Complaint.

WHEREFORE, Third-Party Defendants, Sigmund Tonia and Daryl Fox-Tonia demands

judgment agarnst Third-Parry Plaintiff, Pennrose, LLC, together with reasonable attomey's fees,

legal expenses, costs ofsuit and such other reliefas the Court deems just, equitable and proper.

COUNTTOUR

(Declaratory Judgment)

8I .Denied. This is a paragraph of incorporation which requires no response.

By way offurther response, Third-Party Defendants hereby incorporates by reference all ofthe

preceding paragraphs as though the same were herein set forth at lenglh. To the extent a

respons€ is required, the allegations are denied.

82. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

83. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

84. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Comptaint.

85. Third-Party Defendants deny the allegations in this paragraph of Third-Party Plaintiffs

First Amended Answer and Third-Party Complaint.

86. Third-Party Defendants deny the allegations in this paragraph ofThird-Party Plaintiffs

First Amended Answer and Third-Party Complaint.
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wHEREFORE, Third-Parly Defendants, Sigmund Tonia and Daryl Fox-Tonia demands

judgment against Third-Party Plaintiff, Pemrose, LLC, together with reasonable attorney's fees,

legal expenses, costs ofsuit and such other reliefas the Court deems just, equitable and proper.

FIRST SEPARAI'E DEFENSE
'l'hird-Party Plaintiffs claims are baned by the statute of frauds to the extent that its

claims are based on any contractual obligation which is not embodied in writing.

SECOND SEPARATE DEFf,,NSE

Third-Party Plaintiff failed to state a claim upon which relief may be granted.

THIRD SEPARATE DEFENSE

]'hird-Party Plaintifrs claims are barred by the Statute of Limitations.

FOURTH SEPARATE DEFENSE

Third-Party Plaintiffs claims are baned by the doctrine of estoppel.

FIFTH SEPARATtr DEFf,NSE
'l hird-Party Plainti{fs claims are baned by the doctrine of laches.

SLXTH SEPARA'TE DET'f, NSf,

Third-Party Plaintiffs claitns are barred by the doctrine ol waiver.
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SEVENTH SEPARATE DEFENSE

Third-Party Defendants, Sigmund Tonia and Daryl Fox-Tonia denies every allegation

contained in Third-Party Plaintiff, Pennrose, LLC's First Amended Answer and Third-Party

Complaint not specifically admitted in this answer.

Respectfully submitted,

/
/ ( /)
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ffi-,lrrfirla

-
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RESERVATION OT RIGIITS

Third-Party Defendants, Sigrnund Tonia and Daryl Fox-Tonia reserves the right to assert

or plead any additional alfirmative defenses the availability of which may arise or become

knorvn throughout the course ofthis legal action. Third-Party Defendants, Sigmund Tonia and

Daryl Fox-Tonia are also continuing their investigation, and intend to conduct discovery in this

litigation, and further reserves the right to add parties and to asse( additional causes ofaction.

CERTIFICATION OF SERVICE

We hereby certify that the within Answer was filed and served upon the Third-Party

Plaintiffherein, by first class mai[, postage prcpaid, within the time prescribed by the Rules of

Court.

CERTIFICATION PURSUANT TO RULE 4:$l(b[2)

We ce(ifr, pursuant to New Jersey Court Rule 4:5-l(b)(2) that to the best ofour

knowledge, information and beliefat this time, the matler in controversy is nol the subject ofany

other action pending in any Court nor ofany pending Arbitration proceeding, that no other action

or arbitration is contemplated, and further, thal there are no other parfies who should bejoined in

this action.

Respectfully submitted,
'-l:

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Fox-T
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r',i.-il r,'
...;'

Sigmund . j'
'lai i -if,i '-
Tonia
Daryl Fox-Tonia
l2 Meadow Drive Zri:tHIY l5 lltl l0: 35
Moorestorm, NJ 08057
Pro Se Third-Party Defendants df",.:iYL!
BY, 006
IN THE MATTER OF TI{E APPLICATION SI.JPERIOR COUT OF NEW JERSEY
OF THE TOWNSHIP OF MOORESTOWN, BURLINCTON COUNTY
BURLINGTON COUNTY. LAW DIVISON

PENNROSE, LLC, DOCKETNO. L- r604-15

Third-Party Plaintiff, Civil Action

Vs. ANSWER AND SEPARATE
DEFENSES TO FIRST AMENDED
N PC ASSOCIATES, LLC, ET ALS. ANSWER AND THIRD-PARTY
COMPLAINT
Third-Party Defendants

DEMAND TOR JI]RY TRIAL

Third-Party Defendants, Sigmund Tonia and Daryl Fox-Tonia demand a trial by ajury

on all issues in this civil action.

Respectful submitred,

4
lgm onra
in/

la
Daryl F ox-
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Sigmund Tonia
.' '. : -.:'. (. -.
-
; Llti rli.rir:
1)i J
Daryl Fox-Tonia
12 Meadow Drive
Moorestown, NJ 0E057 ?lii HAY l5 AH l0: 35
Pro Se Third-Parry Defendants
Itiu'--lr'l-u

IN TflE MATTER OF THE APPLICATION SUPERIOR COUT OF NEW JERSEY
OF THE TOWNSHIP OF MOORESTOWN, BURLINGTON COIJNTY
BI.JRLINGTON COUNTY, LAW DIVISON

PENNROSE, LLC, DOCKETNO.L-1604-rs

Third-Party Plaintiff, Civil Action

Vs.
PROOF OF SERVICE
APC ASSOCIATES, LLC, ET ALS,

Third-Party Defendants-

We served Third-Pady Defcndants, Sigmund Tonia and Daryl Fox-Tonia Answer and

Separate Defenses to Third-Party Plaintiff, Pennrose, LLC's First Amended Answer and Third-

Party Complaint by United States first class mail to the following:

Joseph B. Fiorenzo, Esquire
SILLS CUMMIS & GROSS
The Legal Center
One Riverfront Plaza
Newark, NJ 07102
(Counsel for Third-Party Plaintiff, Pennrose, LLC)

Respectfully submitted,

' ' j-,1
r
)
', Daryl ir{
Fox-)6ni a
:,tLy :/./ct
,

-
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Aooendi-x XII-B1

ClvIL CASE INFoRMATIoN STATEMENT PaYMEM rYPrr EIcx Dcc flce
(crs) CHG/CK No.

Use for initial Law Division
Civil Part pleadings (not motions) u ndet Rule 4:5-1 -t--
Pleading will be rejected for tiling,under Ruro 1:5-5{c), OvERPAYMENT:
if information above the black bar is not completed
or attorney's signature is not affixed BA-cH NUiraER:

ATTORNEY I PRO SE tlAl\4E TELEPHONE }.IJMBER COUNTY OF VENUE
Sigmund Tonis / DaM Fox-Toni8 Burllngton
FlRirl nlAI,lE ((
rpdicaue) OOCKET NUMSER (wtEn n ail'Uc)
L-'t60+15
OFFICEAODRESS DOCUMEMT TYPE
Answer

.URY OEMANO T YEs CNO
NAME OF PARTY (..O, John Doe.Ptrintif) CAPTION
Sigmund Tonia / OaM Fox-Tonia, l/lWO APPL T.O.M. I Psflnroso, LLC vs. APC Associales, LLC, ET AL.
Third-Party Def6ndsnts

CASETYPE NUMBER TtrJRRICANE SANDY
(56. ,wa.se rld€ lor li6ting)
RELAIED? ISTIISA PROFESSONAL TIALPRACTICE CASE? O YES I NO

39S
tr YES IIio IF YOU I{AVECIiECXED'YES,'SEE 2453 A.27 A'{D APPUCASLE CASE LATAI
REG RDING YOUROBLGATION IO'{.J.SJ.
FILE All AFFIDAVIToF lvERil
RELATED CASES PENOING? IF YES, LIST OOCKETNU EERS
DYcs INo
DO YOU ANTICIPATE ADOING PART1ES NAte€ oF OEFENOATITE PRIMARY |i€URANCE CO TPANY (if knotl/rt)
(arisr€ out oI sadre lransadbo d^}IY
oagrrence)? I NoN€

E YEs I t\b tr IJNK!{OWI

THE INFORMATION PROVIDEO ON THIS FORTJI CANNOT BE INTROOUCED INTO EVIDENCE.
CASE C|ARACTERISTICS FORPURPOSES OF OETERMINING lF C,qSE lS APPRoPRIATE FOR MEDIATiON
Do FARIES HAVEACURRENT. PAST oR IFTES.iS iH^TNEMMN$IP :

RECURRENT RELANOiIShIP? D 0,PLoYER/ErPtoYEE E FRr€loAtsrcl€cR D On B (exdarr)
E YEs lNo E FArir-a O Bosxrss

OOES T}IE STATUTE GT)],/ERNINGTHIS CASE PROMOE OF FEES AY THE LOSING
FOR PAYI,€I'IT PARTY? E YSS I Tb
USE THIS SPACE TOALERT T}€ COURT TO AJY SPECAL CASE CHARACIERISTICS THAT MAY WARRAMT INDIVIDTAI. i,{AMGEMENT OR
ACCELEFATEO OISPOAINON

5)r
9;';
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Do you ofl youR ct-rENr ots^ar|Iy
t\rEEo ANy AccoMtrtooATloN3? IF YES. PIEAS€ IDENT]FY
TTIE RFOUESTED TlcrN
Cl YEs I lto
BE NEEo€o?
!.y'lt]. AN |NIERPRErER t(x
ts YtB, wHAr LA{GUAGE? cr O
D yEs I tro
I cerlify
that conlldential havc beon rsdaqtld trom document! notr,r submlted to lha cgsr! will bo
.edacled from rll documenta Itt€d uith Rure l:38-7(b).
A'"IORNE SIGMTURE:

Effcctr'w 06/042017, CN 10517 gae1d2
BUR L 001147-18 05/30/2018 Pg 17 of 17 Trans ID: LCV20181038436
BUR L 001604-15 0511512018 Pg '17 of 17 Trans lD: LCY2018877327

Sigmund'fonia
Daryl Fox-Tonia
12 Meadow Drive
Moorestown, NJ 08057
f.
April 16,2018
@2
1'6. L,'
VIA HAND DELIVf,RY " l:
o'-, Z
O;
Clerk's Office
-
6^t't o
Burlington County Courthouse f
49 Rancocas Road
Mount Holly, N.J. 08060

Rs In The Matter of the Application of the
Township of Moorestown, County of Burlinglon

Pennrose LLC vs. APC Associates, Ll-C el al.
S.C.N.J. - Burlinglon County, l.aw Division, Docket No. BUR-L-1604-15

Dear Sir or Madam

Enclosed herein please find Third-Party Defendants, Sigmund Tonia and Daryl Fox-
Tonia Ansrver and Separate Delenses to Third-Party Plaintiffs First Amended Answer and
Third-Party Complaint.

Please time-stamp and retum the enclosed copy.

If you have any questions, please do not hesitate to cor act mc.

Very truly yours,

Sigmund Tonia
Daryl Fox-Tonia
Enclosure
Cc: Sills Cummis & Gross (w/ enclosure)

Case Info

Judge

Paula T Dow Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

May 30, 2018

Case Filing Date

May 30, 2018

County

Parties

Andre Oliveriera Defendant
Annette L Smith Defendant
Anthony P Costa Attorney for the Defendant
Aparecida S Coutinho Defendant
Apc Associates Llc Defendant
Carl Muller Defendant
Carol L Radomski Defendant
Carol Muller Defendant
Chakrya K Molinoff Defendant
Charles Furlong Defendant
Christine E Herb Defendant
Christine Greatrex Defendant
Daniel Hanks Defendant
Daryl F Tonia Defendant
David Hercock Defendant
Diane Speer Defendant
Diego Castellanos Defendant
Doris G Blyler Defendant
Douglas Lynn Heinold Attorney for the Defendant
Edward Mulka Defendant
Elizabeth Falco Defendant
Erika Gore Defendant
Eugene M Flacche Defendant
Eva Hanks Defendant
George C Greatrex Jr Defendant
George Freudenberg Defendant
Giovanna Ferriera Defendant
Hoover Quintero Garcia Defendant
Hui Y Shih Defendant
James E Weist Defendant
Jeffrey B Canfield Defendant
Jeffrey D Herb Defendant
Jeffrey L Molinoff Defendant
Joanne K Welch Defendant
John M Pfrommer Defendant
John S Radomski Defendant
Jose A Coutinho Defendant
Joseph Cavalieri Defendant
Karen Woznica Defendant
Katherine O Schimmel Defendant
Keenan Builders Llc Defendant
Lee H Schimmel Defendant
Margo Furlong Defendant
Marie E Kern Defendant
Mark G Carusillo Attorney for the Defendant
Ming T Shih Defendant
Muir A Mcmath Defendant
Paulette Smith Defendant
Pennrose Llc Plaintiff
Rebecca Castellanos Defendant
Recon Investment Group Llc Defendant
Richard J Perr Attorney for the Plaintiff
Richard J Smith Defendant
Robert Gore Defendant
Robert Woznica Defendant
Ronnie M Tarchichi Defendant
Roseanne M Canfield Defendant
Russell Smith Defendant
Scott G Kern Defendant
Sigmund Tonia Defendant
Susan M Stevens Defendant
Syeda F Ahmed Defendant
Syed M Ahmed Defendant
Theodore J Speer Jr Defendant
Thomas B Mitchell Defendant
Umur Selek Defendant
Vito Brasile Defendant
Warren G Blyler Defendant
Wongsduan Mulka Defendant
Joseph Fiorenzo Attorneys for Plaintiffs
Victor Herlinsky Attorney
Mark Guralnick Attorney
Meryl Gonchar Attorneys for Defendants
ANTHONY COCCA Attorney

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Answer: Pennrose Llc Vs Apc Associates Llc

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