On May 30, 2018 a
Request,Application
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
BUR L 001147-18 04/17/2019 Pg 1 of5 Trans ID: LCV2019708500
BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 1 of 4 Trans ID: LCV2019680013
SILLS CUMMIS & GROSS, P.C.
One Riverfront Plaza
Newark, New Jersey 07102 TO ENTER DEFAGL..
Meryl A.G. Gonchar, Esq. DEFAULT HAS GEEN
Attorney ID# 022571981 AS T HE PILED BE: EST
Email: mgonchar@sillscummis.com OF, .
4i
Joseph B. Fiorenzo, Esq.
Attorney ID# 021421980
Michelle M. Smith, Esq.
Email: jfiorenzo@sillscummis.com
(973) 643-7000 SUPERIOR
COURT OF N.dia”
Attorneys for Plaintiff,
Pennrose, LLC
PENNROSE, LLC, SUPERIOR COURT OF NEW JERSEY
Plaintiff, BURLINGTON COUNTY
LAW DIVISION
Vv.
DOCKET NO. L-1147-18
APC ASSOCIATES, LLC; et al.,
Defendants. CIVIL ACTION
STIPULATION ENTERING DEFAULT
AGAINST APC ASSOCIATES, LLC
THIS MATTER having been opened by Sills, Cummis & Gross P.C., attorneys for
plaintiff, Pennrose, LLC (“Pennrose”);
WHEREAS, on or about March 5, 2018, Pennrose filed this action as a Third-Party
Complaint to the declaratory judgment action filed by the Township of Moorestown in In_re
Application of the Township of Moorestown, County of Burlington, Docket No. BUR-L-1604-
15; and
WHEREAS the Third-Party Complaint has since been severed from the declaratory
judgment action and is now proceeding independently under Docket No. BUR-L-1147-18; and
WHEREAS, defendant APC Associates, LLC was served with the Summons and
Amended Answer and Third-Party Complaint of Pennrose, LLC on March 9, 2018, as set forth
on the attached Acknowledgement of Service;
Error! Unknown document property name,
BUR L 001147-18 04/17/2019 Pg 2 of5 Trans ID: LCV2019708500
AD
cs
¥E
VR 5
1? Toes
ee ee
LL WO THUG wt
BUR L 001147-18 04/17/2019 Pg 3 of5 Trans ID: LCV2019708500
BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 2of 4 Trans ID: LCV2019680013
WHEREAS, the time within which defendant APC Associates, LLC may answer or
otherwise move as to the said Third-Party Complaint has expired, and has not been extended or
enlarged; and
WHEREAS, APC Associates, LLC has no intention to file an Answer or otherwise move
as to the Third-Party Complaint;
NOW THEREFORE, it is stipulated and agreed by and between plaintiff, Pennrose, LLC,
and defendant APC Associates, LLC as follows:
1 Default be and hereby is entered against defendant APC Associates, LLC; and
2 The Clerk of the Court shall enter on the docket default against defendant APC
Associates, LLC.
SILLS CUMMIS & GROSS P.C. LAW OFFICE OF ANTHONY P. COSTA, ESQ.
Attorneys for Plaintiff Attorneys for Defendant
Pennrose LLC APC Associates, LC
B By:
Ke
KRISTOFFER S. BURFITT ANTHONY P. COSTA
Dated: March __, 2019 Dated: March /1, 2019
Error! Unknown document property name.
BUR L 001147-18 04/17/2019 Pg 4 of 5 Trans ID: LCV2019708500
BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 3 of 4 Trans ID: LCV2019680013
SILLS CUMMIS & GROSS, P.C.
One Riverfront Plaza
Newark, New Jersey 07102
Meryl A.G. Gonchar, Esq.
Attorney ID# 022571981
Email: mgonchar@sillscummis.com
Joseph B. Fiorenzo, Esq.
Attorney ID# 021421980
Email: jfiorenzo@sillscummis.com
(973) 643-7000
Attorneys for Intervenor-Defendant / Third-Party Plaintiff,
Pennrose, LLC
IN THE MATTER OF THE SUPERIOR COURT OF NEW JERSEY
APPLICATION OF THE TOWNSHIP | BURLINGTON COUNTY
OF MOORESTOWN, COUNTY OF | LAW DIVISION
BURLINGTON
DOCKET NO. L-1604-15
PENNROSE, LLC, (Mount Laurel)
Third-Party Plaintiff, CIVIL ACTION
Vv.
APC ASSOCIATES, LLC, et als., ACKNOWLEDGEMENT OF SERVICE
Third-Party Defendants.
Third-Party Defendant APC Associates, LLC hereby acknowledges service of the
Summons and Amended Answer and Third-Party Complaint of Pennrose, LLC.
LityGias.
Title: MAMp05 Pande ARO KA ecrety
Dated: 3-GA8
5195411 v1
BUR L 001147-18 04/17/2019 Pg 5 of5 Trans ID: LCV2019708500
BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 4 of 4 Trans ID: LCV2019680013
SUMMONS
Attomey(s) Joseph B. Fiorenzo, Esq.
Superior Court of
Office Address One Riverfront Plaza
Town, State, Zip Code Newark, NJ 07102 New Jersey
Burlington County
Telephone Number 973-643-7000 Law Division
Attorney(s) for Plaintiff Pennrose, LLC Docket No: L-1604-15
Pennrose, LLC
Plaintiff(s)
CIVIL ACTION
vs. SUMMONS
APC Associates, LLC, et als.
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 Dis ision Management Office in the county listed above and online at
ttp://www.nicourts.gov/forms/10153_deptyclerklawref.pdf.) 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://ww) courts.gov/forms/10153_deptyclerklawref.pdf.
/s/ Michelle M. Smith
Clerk of the Superior Court
DATED: 03/05/2018
Name of Defendant to Be Served: APC Associates, LLC
Address of Defendant to Be Served: 5 Atherton Court, Laure! Springs, NJ 08021
Revised 11/17/2014, CN 10792-English (Appendix XII-A)
Preview
BUR L 001147-18 04/17/2019 Pg 1 of5 Trans ID: LCV2019708500 BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 1 of 4 Trans ID: LCV2019680013 SILLS CUMMIS & GROSS, P.C. One Riverfront Plaza Newark, New Jersey 07102 TO ENTER DEFAGL.. Meryl A.G. Gonchar, Esq. DEFAULT HAS GEEN Attorney ID# 022571981 AS T HE PILED BE: EST Email: mgonchar@sillscummis.com OF, . 4i Joseph B. Fiorenzo, Esq. Attorney ID# 021421980 Michelle M. Smith, Esq. Email: jfiorenzo@sillscummis.com (973) 643-7000 SUPERIOR COURT OF N.dia” Attorneys for Plaintiff, Pennrose, LLC PENNROSE, LLC, SUPERIOR COURT OF NEW JERSEY Plaintiff, BURLINGTON COUNTY LAW DIVISION Vv. DOCKET NO. L-1147-18 APC ASSOCIATES, LLC; et al., Defendants. CIVIL ACTION STIPULATION ENTERING DEFAULT AGAINST APC ASSOCIATES, LLC THIS MATTER having been opened by Sills, Cummis & Gross P.C., attorneys for plaintiff, Pennrose, LLC (“Pennrose”); WHEREAS, on or about March 5, 2018, Pennrose filed this action as a Third-Party Complaint to the declaratory judgment action filed by the Township of Moorestown in In_re Application of the Township of Moorestown, County of Burlington, Docket No. BUR-L-1604- 15; and WHEREAS the Third-Party Complaint has since been severed from the declaratory judgment action and is now proceeding independently under Docket No. BUR-L-1147-18; and WHEREAS, defendant APC Associates, LLC was served with the Summons and Amended Answer and Third-Party Complaint of Pennrose, LLC on March 9, 2018, as set forth on the attached Acknowledgement of Service; Error! Unknown document property name, BUR L 001147-18 04/17/2019 Pg 2 of5 Trans ID: LCV2019708500 AD cs ¥E VR 5 1? Toes ee ee LL WO THUG wt BUR L 001147-18 04/17/2019 Pg 3 of5 Trans ID: LCV2019708500 BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 2of 4 Trans ID: LCV2019680013 WHEREAS, the time within which defendant APC Associates, LLC may answer or otherwise move as to the said Third-Party Complaint has expired, and has not been extended or enlarged; and WHEREAS, APC Associates, LLC has no intention to file an Answer or otherwise move as to the Third-Party Complaint; NOW THEREFORE, it is stipulated and agreed by and between plaintiff, Pennrose, LLC, and defendant APC Associates, LLC as follows: 1 Default be and hereby is entered against defendant APC Associates, LLC; and 2 The Clerk of the Court shall enter on the docket default against defendant APC Associates, LLC. SILLS CUMMIS & GROSS P.C. LAW OFFICE OF ANTHONY P. COSTA, ESQ. Attorneys for Plaintiff Attorneys for Defendant Pennrose LLC APC Associates, LC B By: Ke KRISTOFFER S. BURFITT ANTHONY P. COSTA Dated: March __, 2019 Dated: March /1, 2019 Error! Unknown document property name. BUR L 001147-18 04/17/2019 Pg 4 of 5 Trans ID: LCV2019708500 BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 3 of 4 Trans ID: LCV2019680013 SILLS CUMMIS & GROSS, P.C. One Riverfront Plaza Newark, New Jersey 07102 Meryl A.G. Gonchar, Esq. Attorney ID# 022571981 Email: mgonchar@sillscummis.com Joseph B. Fiorenzo, Esq. Attorney ID# 021421980 Email: jfiorenzo@sillscummis.com (973) 643-7000 Attorneys for Intervenor-Defendant / Third-Party Plaintiff, Pennrose, LLC IN THE MATTER OF THE SUPERIOR COURT OF NEW JERSEY APPLICATION OF THE TOWNSHIP | BURLINGTON COUNTY OF MOORESTOWN, COUNTY OF | LAW DIVISION BURLINGTON DOCKET NO. L-1604-15 PENNROSE, LLC, (Mount Laurel) Third-Party Plaintiff, CIVIL ACTION Vv. APC ASSOCIATES, LLC, et als., ACKNOWLEDGEMENT OF SERVICE Third-Party Defendants. Third-Party Defendant APC Associates, LLC hereby acknowledges service of the Summons and Amended Answer and Third-Party Complaint of Pennrose, LLC. LityGias. Title: MAMp05 Pande ARO KA ecrety Dated: 3-GA8 5195411 v1 BUR L 001147-18 04/17/2019 Pg 5 of5 Trans ID: LCV2019708500 BUR-L-001147-18 04/17/2019 9:35:40 AM Pg 4 of 4 Trans ID: LCV2019680013 SUMMONS Attomey(s) Joseph B. Fiorenzo, Esq. Superior Court of Office Address One Riverfront Plaza Town, State, Zip Code Newark, NJ 07102 New Jersey Burlington County Telephone Number 973-643-7000 Law Division Attorney(s) for Plaintiff Pennrose, LLC Docket No: L-1604-15 Pennrose, LLC Plaintiff(s) CIVIL ACTION vs. SUMMONS APC Associates, LLC, et als. 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 Dis ision Management Office in the county listed above and online at ttp://www.nicourts.gov/forms/10153_deptyclerklawref.pdf.) 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://ww) courts.gov/forms/10153_deptyclerklawref.pdf. /s/ Michelle M. Smith Clerk of the Superior Court DATED: 03/05/2018 Name of Defendant to Be Served: APC Associates, LLC Address of Defendant to Be Served: 5 Atherton Court, Laure! Springs, NJ 08021 Revised 11/17/2014, CN 10792-English (Appendix XII-A)