Preview
UNN L 003128-16 08/24/2017 Pg 1 of5 Trans ID: LCV2017230815
UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 1 of 5 Trans ID: LCV2017145267
RECEIVED/
Superior Court Of Ne
w Jey
AUG 24 2017
CIVIL CASE Mal AG
PETER DeSALVO, JR., 017581977 EMENT
UNION Ci OUNTY
SORIANO, HENKEL, BIEHL & MATTHEWS
75 Bisenhower Parkway
Roseland, New Jersey 07068-1693
(973) 364-0111
Attorneys for Defendant, Stamper
IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION - UNION COUNTY
Plaintiff, DOCKET NO. UNN-L-2085-16
vs.
AARON STAMPER, ANIEMA A.
EKWERE, John Doe #1-10, Jane
Roe #1-10 and ABC Company #1-
10, said names being
fictitious),
Defendants.
ANIEMA A. EKWERE, SUPERIOR COURT OF NE SEY
LAW DIVISION — ION COU!
Plaintiff, DOCKET NO. UNNFL-3128-16
vs.
AARON STAMPER and JOHN DOES
1-10, unknown individuals
responsible for the accident
in question,
Defendants.
CIVIL ACTION - NOTICE OF MOTION
TO Nicholas P. Scutari, Esq.
1514 East St. Georges Avenue
Linden, New Jersey 07036
Attorney for Plaintiff, Ekwere
ON NOTICE TO:
Ann Merritt, Esq.
Tobin, Kessler, Greenstein,
Caruso, Wiener & Konray
UNN L 003128-16 08/24/2017 Pg 2 of5 Trans ID: LCV2017230815
UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 2 of 5 Trans ID: LCV2017145267
136 Central Avenue
Clark, New Jersey 07066
Attorney for Plaintiff, Obodeh
Steven Greenberg, Esq.
Law Office of Debra Hart
5006A Belmar Boulevard
Wall, New Jersey 07727
Attorney for Defendant, Ekwere
COUNSEL:
PLEASE TAKE NOTICE that on September 15, 2017, the
undersigned, attorney for the defendant, Stamper, will move before
the Superior Court, Law Division, Union County, for an order
compelling the plaintiff, Aniema Ekwere, to appear and to submit to
an oral deposition.
In support of this motion the undersigned will rely solely on
the annexed certification and waives oral argument pursuant to
R.1:6-2.
Please be advised that there has been no date set for
pre-trial conference, calendar call or daily call in
arbitration,
the above matter. The discovery end date is October 7, 2017.
PETER DeSALVO, JR.
PETER DeSALVO, JR.
Dated: August 24, 2017
UNN L 003128-16 08/24/2017 Pg 3 of5 Trans ID: LCV2017230815
UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 3 of 5 Trans ID: LCV2017145267
PETER DeSALVO, JR., 017581977
SORIANO, HENKEL, BIEHL & MATTHEWS
75 Eisenhower Parkwa
Roseland, New Jersey 07068-1693
(973) 364-0111
Attorneys for Defendant, Stamper
IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION - UNION COUNTY
Plaintiff, DOCKET NO. UNN~L-2085-16
vs.
AARON STAMPER, ANIEMA A.
EKWERE, John Doe #1-10, Jane
Roe #1-10 and ABC Company #1-
10, said names being
fictitious),
Defendants.
ee SSSsSSeeeseese
ANIEMA A. EKWERE, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION ~ UNION COUNTY
Plaintiff, DOCKET NO. UNN-L-3128-16
vs.
AARON STAMPER and JOHN DOES
1-10, unknown individuals
responsible for the accident
in question,
Defendants.
CIVIL ACTION - PROOF OF MAILING
hereby certify that the original of this motion has been
I
with the Union County Clerk and a copy was
filed electronically
served on the attorneys for all parties listed above electronically
and by regular mail on August 24, 2017.
PETER DeSALVO, JR.
PETER DeSALVO, JR.
Dated: August 24, 2017
UNN L 003128-16 08/24/2017 Pg 4 of5 Trans ID: LCV2017230815
UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 4 of § Trans ID: LCV2017145267
RECEIVED /
Superier Court cf New Jersey
PETER DeSALVO, JRey 017581977 Aue 24 2017
SORIANO, HENKEL, BIEHL & MATTHEWS
MENT
75 Eisenhower Parkway CIVIL CASE MANAGE
UNI ON CO UN TY
Roseland, New Jersey 07068-1693
(973) 364-0111
Attorneys for Defendant, Stamper
eee
IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION - UNION COUNTY
Plaintiff, DOCKET NO. UNN-L-2085-16
vs.
AARON STAMPER, ANIEMA A.
EKWERE, John Doe #1-10, Jane
Roe #1-10 and ABC Company #1-
10, said names being
fictitious),
Defendants.
eee
ANIEMA A. EKWERE, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION - UNION COUNTY
Plaintiff, DOCKET NO. UNN-L-3128-16
vs.
AARON STAMPER and JOHN DOES
1-10, unknown individuals
responsible for the accident
in question,
Defendants.
CIVIL ACTION - CERTIFICATION
PETER DeSALVO, JR., hereby certify as follows:
I,
at law of the State of New Jersey, of
1 I am an attorney
of Soriano, Henkel, Biehl and Matthews, and as such I
the law firm
the representation of the defendant, Stamper, in
am responsible for
the above consolidated matters.
matters arise from a motor vehicle accident which
2 These
26, 2014. Suit has been instituted on behalf
occurred on October
UNN L 003128-16 08/24/2017 Pg 5 of5 Trans ID: LCV2017230815
UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 5 of 5 Trans ID: LCV2017145267
of the piaintiff, Ekwere, alleging personal injuries arising from
said accident.
3 The deposition of the plaintiff, Ekwere, had been
scheduled on numerous occasions, including, but not limited to May
24, June 27, July 12, and August 24, 2017. In each instance the
deposition of the plaintiff, Ekwere, was adjourned by counsel for
plaintiff. The letters rescheduling the deposition advised that
counsel that if the deposition continued to be adjourned, I would
file a motion seeking the appropriate relief from the Court.
4 Accordingly, I request that this court enter an Order
compelling the plaintiff, Aniema Ekwere, to appear at the offices
of Nicholas P. Scutari, Esq., 1514 East St. Georges Avenue, Linden,
New Jersey on September 27, 2017 at 2:00 p.m. to submit to an oral
deposition.
I hereby certify that the foregoing statements made by me are
true. I am aware that if any of the foregoing statements made by
me are willfully false, I am subject to punishment.
PETER DeSALVO, JR.
PETER DeSALVO, JR.
Dated: August 24, 2017
Preview
UNN L 003128-16 08/24/2017 Pg 1 of5 Trans ID: LCV2017230815 UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 1 of 5 Trans ID: LCV2017145267 RECEIVED/ Superior Court Of Ne w Jey AUG 24 2017 CIVIL CASE Mal AG PETER DeSALVO, JR., 017581977 EMENT UNION Ci OUNTY SORIANO, HENKEL, BIEHL & MATTHEWS 75 Bisenhower Parkway Roseland, New Jersey 07068-1693 (973) 364-0111 Attorneys for Defendant, Stamper IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY LAW DIVISION - UNION COUNTY Plaintiff, DOCKET NO. UNN-L-2085-16 vs. AARON STAMPER, ANIEMA A. EKWERE, John Doe #1-10, Jane Roe #1-10 and ABC Company #1- 10, said names being fictitious), Defendants. ANIEMA A. EKWERE, SUPERIOR COURT OF NE SEY LAW DIVISION — ION COU! Plaintiff, DOCKET NO. UNNFL-3128-16 vs. AARON STAMPER and JOHN DOES 1-10, unknown individuals responsible for the accident in question, Defendants. CIVIL ACTION - NOTICE OF MOTION TO Nicholas P. Scutari, Esq. 1514 East St. Georges Avenue Linden, New Jersey 07036 Attorney for Plaintiff, Ekwere ON NOTICE TO: Ann Merritt, Esq. Tobin, Kessler, Greenstein, Caruso, Wiener & Konray UNN L 003128-16 08/24/2017 Pg 2 of5 Trans ID: LCV2017230815 UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 2 of 5 Trans ID: LCV2017145267 136 Central Avenue Clark, New Jersey 07066 Attorney for Plaintiff, Obodeh Steven Greenberg, Esq. Law Office of Debra Hart 5006A Belmar Boulevard Wall, New Jersey 07727 Attorney for Defendant, Ekwere COUNSEL: PLEASE TAKE NOTICE that on September 15, 2017, the undersigned, attorney for the defendant, Stamper, will move before the Superior Court, Law Division, Union County, for an order compelling the plaintiff, Aniema Ekwere, to appear and to submit to an oral deposition. In support of this motion the undersigned will rely solely on the annexed certification and waives oral argument pursuant to R.1:6-2. Please be advised that there has been no date set for pre-trial conference, calendar call or daily call in arbitration, the above matter. The discovery end date is October 7, 2017. PETER DeSALVO, JR. PETER DeSALVO, JR. Dated: August 24, 2017 UNN L 003128-16 08/24/2017 Pg 3 of5 Trans ID: LCV2017230815 UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 3 of 5 Trans ID: LCV2017145267 PETER DeSALVO, JR., 017581977 SORIANO, HENKEL, BIEHL & MATTHEWS 75 Eisenhower Parkwa Roseland, New Jersey 07068-1693 (973) 364-0111 Attorneys for Defendant, Stamper IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY LAW DIVISION - UNION COUNTY Plaintiff, DOCKET NO. UNN~L-2085-16 vs. AARON STAMPER, ANIEMA A. EKWERE, John Doe #1-10, Jane Roe #1-10 and ABC Company #1- 10, said names being fictitious), Defendants. ee SSSsSSeeeseese ANIEMA A. EKWERE, SUPERIOR COURT OF NEW JERSEY LAW DIVISION ~ UNION COUNTY Plaintiff, DOCKET NO. UNN-L-3128-16 vs. AARON STAMPER and JOHN DOES 1-10, unknown individuals responsible for the accident in question, Defendants. CIVIL ACTION - PROOF OF MAILING hereby certify that the original of this motion has been I with the Union County Clerk and a copy was filed electronically served on the attorneys for all parties listed above electronically and by regular mail on August 24, 2017. PETER DeSALVO, JR. PETER DeSALVO, JR. Dated: August 24, 2017 UNN L 003128-16 08/24/2017 Pg 4 of5 Trans ID: LCV2017230815 UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 4 of § Trans ID: LCV2017145267 RECEIVED / Superier Court cf New Jersey PETER DeSALVO, JRey 017581977 Aue 24 2017 SORIANO, HENKEL, BIEHL & MATTHEWS MENT 75 Eisenhower Parkway CIVIL CASE MANAGE UNI ON CO UN TY Roseland, New Jersey 07068-1693 (973) 364-0111 Attorneys for Defendant, Stamper eee IZEHINOSEN OBODEH, SUPERIOR COURT OF NEW JERSEY LAW DIVISION - UNION COUNTY Plaintiff, DOCKET NO. UNN-L-2085-16 vs. AARON STAMPER, ANIEMA A. EKWERE, John Doe #1-10, Jane Roe #1-10 and ABC Company #1- 10, said names being fictitious), Defendants. eee ANIEMA A. EKWERE, SUPERIOR COURT OF NEW JERSEY LAW DIVISION - UNION COUNTY Plaintiff, DOCKET NO. UNN-L-3128-16 vs. AARON STAMPER and JOHN DOES 1-10, unknown individuals responsible for the accident in question, Defendants. CIVIL ACTION - CERTIFICATION PETER DeSALVO, JR., hereby certify as follows: I, at law of the State of New Jersey, of 1 I am an attorney of Soriano, Henkel, Biehl and Matthews, and as such I the law firm the representation of the defendant, Stamper, in am responsible for the above consolidated matters. matters arise from a motor vehicle accident which 2 These 26, 2014. Suit has been instituted on behalf occurred on October UNN L 003128-16 08/24/2017 Pg 5 of5 Trans ID: LCV2017230815 UNN-L-003128-16 08/24/2017 8:30:15 AM Pg 5 of 5 Trans ID: LCV2017145267 of the piaintiff, Ekwere, alleging personal injuries arising from said accident. 3 The deposition of the plaintiff, Ekwere, had been scheduled on numerous occasions, including, but not limited to May 24, June 27, July 12, and August 24, 2017. In each instance the deposition of the plaintiff, Ekwere, was adjourned by counsel for plaintiff. The letters rescheduling the deposition advised that counsel that if the deposition continued to be adjourned, I would file a motion seeking the appropriate relief from the Court. 4 Accordingly, I request that this court enter an Order compelling the plaintiff, Aniema Ekwere, to appear at the offices of Nicholas P. Scutari, Esq., 1514 East St. Georges Avenue, Linden, New Jersey on September 27, 2017 at 2:00 p.m. to submit to an oral deposition. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. PETER DeSALVO, JR. PETER DeSALVO, JR. Dated: August 24, 2017