On March 22, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Jeffrey Bello,
and
0 Abc Corporations 1-1,
Airsept Inc,
Cadillac,
Chris C Roffey,
Daniel E Berce,
Esis Inc,
General Motors Financial Compa,
General Motors Holdings Llc,
General Motors Llc,
Holman Cadillac,
Jane Does 1-10,
John Does 1-10,
John Nevitt,
Joshua Preister,
Kerbeck Cadillac Inc,
Mary T Barra,
Melinda K Holman,
Michael Schwab,
Patrick R Burley,
Product Defense Investigative,
Steven Mattern,
Tammy Ward,
for Product Liability
in the District Court of Burlington County.
Preview
BUR-L-000638-18 08/18/2020 9:36:02 AM Pg 1 of 1 Trans ID: LCV20201435252
1515 MARKET STREET 750 ROUTE 73 SOUTH
SUITE 700 SUITE 202B
PHILADELPHIA, PA 19102 MARLTON, NJ 08053
TEL 215.320.3260 TEL 856.810.8860
FAX 215.320.3261 FAX 856.810.8861
Monica V. Pennisi Marsico., Esquire
Direct Dial: (215) 320-2083
E-Mail: mpmarsico@rtjglaw.com
August 18, 2020
VIA ELECTRONIC FILING
The Honorable Janet Z. Smith, J.S.C.
Burlington County Office Building
49 Rancocas Road, 4th Floor
Mount Holly, NJ 08060
RE: Jeffrey Bello v. General Motors LLC, et al.
Superior Court of New Jersey, Burlington County
Docket No. BUR L 638-18
Our File No.: 7614.00043
Dear Judge Smith:
This office is counsel for General Motors LLC, ESIS, Inc., Holman Cadillac and Kerbeck
Cadillac in the above-referenced matter. A case management conference was held in this matter
on August 14, 2020. It was realized after the conference that the dispositive motion deadline of
April 1, 2021 set by the Court will require a trial date later than the May 9, 2021 date that was
also set. Rule 4:46-1 provides that all summary judgment motions “shall be returnable no later
than 30 days before the scheduled trial date.” Assuming filing on April 1st, the earliest possible
return date for a dispositive motion would be April 30, 2021, only 9 days before trial. Given this,
it is respectfully requested that the Court reschedule the May 9, 2021 trial date to late June or
early July 2021.
Thank you for your attention to this matter.
Respectfully submitted,
Monica V. Pennisi Marsico
Monica V. Pennisi Marsico
MPM/ceb
cc: Jeffrey M. Bello (via electronic mail)
David G Murphy, Esquire (via electronic mail)
Anne M. Dalena, Esquire (via electronic mail)
Document Filed Date
August 18, 2020
Case Filing Date
March 22, 2018
Category
Product Liability
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BUR-L-000638-18 08/18/2020 9:36:02 AM Pg 1 of 1 Trans ID: LCV20201435252 1515 MARKET STREET 750 ROUTE 73 SOUTH SUITE 700 SUITE 202B PHILADELPHIA, PA 19102 MARLTON, NJ 08053 TEL 215.320.3260 TEL 856.810.8860 FAX 215.320.3261 FAX 856.810.8861 Monica V. Pennisi Marsico., Esquire Direct Dial: (215) 320-2083 E-Mail: mpmarsico@rtjglaw.com August 18, 2020 VIA ELECTRONIC FILING The Honorable Janet Z. Smith, J.S.C. Burlington County Office Building 49 Rancocas Road, 4th Floor Mount Holly, NJ 08060 RE: Jeffrey Bello v. General Motors LLC, et al. Superior Court of New Jersey, Burlington County Docket No. BUR L 638-18 Our File No.: 7614.00043 Dear Judge Smith: This office is counsel for General Motors LLC, ESIS, Inc., Holman Cadillac and Kerbeck Cadillac in the above-referenced matter. A case management conference was held in this matter on August 14, 2020. It was realized after the conference that the dispositive motion deadline of April 1, 2021 set by the Court will require a trial date later than the May 9, 2021 date that was also set. Rule 4:46-1 provides that all summary judgment motions “shall be returnable no later than 30 days before the scheduled trial date.” Assuming filing on April 1st, the earliest possible return date for a dispositive motion would be April 30, 2021, only 9 days before trial. Given this, it is respectfully requested that the Court reschedule the May 9, 2021 trial date to late June or early July 2021. Thank you for your attention to this matter. Respectfully submitted, Monica V. Pennisi Marsico Monica V. Pennisi Marsico MPM/ceb cc: Jeffrey M. Bello (via electronic mail) David G Murphy, Esquire (via electronic mail) Anne M. Dalena, Esquire (via electronic mail)