Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 1 of 17 PageID: 6
`
`
`Exhibit A
`
`

`

`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 2 of 17 PageID: 7
`
`Service of Process
`Transmittal
`12/01/2021
`CT Log Number 540669063
`
`TO:
`
`RE:
`
`FOR:
`
`Desiree Beatty
`Aetna, Inc.
`Law U23S, 1425 Union Meeting Road
`Blue Bell, PA 19422
`
`Process Served in Connecticut
`
`Aetna Inc.  (Domestic State: PA)
`
`ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:
`
`TITLE OF ACTION:
`
`ADVANCED ORTHOPEDICS & HAND SURGERY INSTITUTE, vs. AETNA, INC.,
`
`DOCUMENT(S) SERVED:
`
`--
`
`COURT/AGENCY:
`
`NATURE OF ACTION:
`
`None Specified
`Case # BERL00752621
`
`Insurance Litigation
`
`ON WHOM PROCESS WAS SERVED:
`
`C T Corporation System, East Hartford, CT
`
`DATE AND HOUR OF SERVICE:
`
`By Process Server on 12/01/2021 at 14:13
`
`JURISDICTION SERVED :
`
`APPEARANCE OR ANSWER DUE:
`
`ATTORNEY(S) / SENDER(S):
`
`ACTION ITEMS:
`
`Connecticut
`
`None Specified
`
`None Specified
`
`CT has retained the current log, Retain Date: 12/01/2021, Expected Purge Date:
`12/06/2021
`
`Image SOP
`
`Email Notification,  Desiree Beatty  beattyd@aetna.com
`
`Email Notification,  Jacqueline West  westj2@aetna.com
`
`Email Notification,  Piper Taylor  plperry@aetna.com
`
`Email Notification,  Kim DePaepe  kjdepaepe@aetna.com
`
`Email Notification,  John Baka  bakaj@aetna.com
`
`REGISTERED AGENT ADDRESS:
`
`C T Corporation System
`67 Burnside Ave
`East Hartford, CT 06108
`800-448-5350
`MajorAccountTeam1@wolterskluwer.com
`The information contained in this Transmittal is provided by CT for quick reference only. It does not constitute a legal opinion, and should not otherwise be
`relied on, as to the nature of action, the amount of damages, the answer date, or any other information contained in the included documents. The recipient(s)
`of this form is responsible for reviewing and interpreting the included documents and taking appropriate action, including consulting with its legal and other
`
`Page 1 of  2 / HS
`
`

`

`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 3 of 17 PageID: 8
`
`Service of Process
`Transmittal
`12/01/2021
`CT Log Number 540669063
`
`TO:
`
`RE:
`
`FOR:
`
`Desiree Beatty
`Aetna, Inc.
`Law U23S, 1425 Union Meeting Road
`Blue Bell, PA 19422
`
`Process Served in Connecticut
`
`Aetna Inc.  (Domestic State: PA)
`
`advisors as necessary. CT disclaims all liability for the information contained in this form, including for any omissions or inaccuracies that may be contained
`therein.
`
`Page 2 of  2 / HS
`
`

`

`11/30/21, 1:04 PM
`
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 4 of 17 PageID: 9
`onlineBusinessSearch
`
`AETNA INC. ACTIVE
`151 FARMINGTON AVENUE, HARTFORD, CT, 06156, United States
`
`BUSINESS DETAILS
`
`Business Details
`
`General Information
`
`Business Name
`
`AETNA INC.
`
`Business status
`
`ACTIVE
`
`Citizenship/place of formation
`
`Foreign/PA
`
`Business address
`
`151 FARMINGTON AVENUE, HARTFORD, CT, 06156, United States
`
`Annual report due
`12/13/2022
`
`N AICS code
`
`Offices of Other Holding Companies (551112)
`
`Business ALEI
`
`0668349
`
`Date formed
`
`12/13/2000
`
`B usiness type
`
`Stock
`
`M ailing address
`
`151 FARMINGTON AVENUE RW61, HARTFORD, CT, 06156, United States
`
`Last report filed
`
`2021
`
`N AICS sub code
`
`551112
`
`Principal Details
`
`Principal Name
`
`CAROL ANN DENALE
`
`Principal Title
`
`DIRECTOR/TREASURER
`
`Principal Business address
`
`151 FARMINGTON AVENUE, HARTFORD, CT, 06156, United States
`
`https://service.agov/business/s/onlinebusinesssearch?businessName.Aetna%2C Inc*
`
`1/12
`
`

`

`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 5 of 17 PageID: 10
`11/30/21, 1:05 PM
`onlineBusinessSearch
`
`Date generated
`
`12/18/2000
`
`I nterim Notice - Interim Notice
`
`0002195298
`Filing date: 12/26/2000
`
`Volume Type
`
`Volume
`
`381
`
`Start page
`
`977
`
`Pages
`
`3 D
`
`ate generated
`
`12/26/2000
`
`Annual Report(2001)
`
`0002361451
`
`Filing date: 1/7/2002
`
`Volume Type
`
`Volume
`
`464
`
`Start page
`
`2907
`
`Pages
`
`ate generated
`
`2 D
`
`1/7/2002
`
`Annual Report(2002)
`
`0002579366
`
`Filing date: 2/6/2003
`
`Volume Type
`
`Volume
`
`578
`
`Start page
`
`2797
`
`Pages
`
`3 D
`
`ate generated
`
`2/6/2003
`
`https://service.agov/business/s/onlinebusinesssearch?businessName.Aetne/o2C Inc*
`
`4/12
`
`

`

`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 6 of 17 PageID: 11
`
`SUMMONS
`
`Attorney(s) Lawall & Mitchell, LLC
`
`Office Address 55 Madison Avenue
`
`Town, State, Zip Code Morristown, New Jersey 07960
`
`Superior Court of
`New Jersey
`
`Bergen
`Telephone Number 973-285-3280 Civil
` Docket No: BER-L-007526-21
`
` County
`
` Division
`
`Attorney(s) for Plaintiff
`
`ADVANCED ORTHOPEDICS &
`HAND SURGERY INSTITUTE,
`
`Plaintiff(s)
`
`vs.
`AETNA, INC., JOHN DOES 1-10,
`JANE DOES 1-10 AND ABC CORPORATIONS 1-10,
`
`Defendant(s)
`
`From The State of New Jersey To The Defendant(s) Named
`Above:
`
`CIVIL ACTION
`SUMMONS
`
`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 Division Management Office in the county listed above and online at
`http://www.njcourts.gov/forms/10153_deptyc1erk1awref.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://www.njcourts.gov/forms/10153 deptycl erklawref.pdf.
`
`/s/ Michelle M. Smith
`
`DATED: November 17, 2021 Name
`
`of Defendant to Be Serve
`
`Aetna, Inc.
`
`Address of Defendant to Be e
`
`151 Farmington Avenue, Hartford, CT 06156
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 1 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 7 of 17 PageID: 12
`
`X .
`
` SUPERIOR COURT OF NEW JERSEY
`: LAW DIVISION: BERGEN COUNTY
`
`Lawall & Mitchell, LLC
`Dara J. Lawall, Esquire (ID. #028332008)
`55 Madison Avenue
`Morristown, New Jersey 07960
`Attorneys for Plaintiff
`973-285-3280
`
`ADVANCED ORTHOPEDICS & HAND
`SURGERY INSTITUTE,
`
`Plaintiff,
`
`VS.
`
`: DOCKET NO.:
`
`CIVIL ACTION
`
`AETNA, INC., JOHN DOES 1-10, JANE
`DOES 1-10, AND ABC CORPORATIONS 1-
`10,
`
`• COMPLAINT, JURY DEMAND AND
`. DESIGNATION OF TRIAL COUNSEL
`
`Defendants.
`
`X
`
`Plaintiff Advanced Orthopedics & Hand Surgery Institute, by and through its attorneys,
`
`Lawall and Mitchell, LLC and as and for its Complaint against Defendants Aetna, Inc., John Does
`
`1-10, Jane Does 1-10, and ABC Corporations 1-10, says:
`
`THE PARTIES
`
`1.
`
`Plaintiff Advanced Orthopedics & Hand Surgery Institute (hereinafter referred to
`
`as "AOHSI "and "Plaintiff') with a business address of 504 Valley Road, City of Wayne, County
`
`of Passaic, and State of New Jersey, is now and was at all times relevant to this action, a company
`
`organized and operating under the Laws of the State of New Jersey, providing healthcare services.
`
`2.
`
`Upon information and belief, at all relevant times, Defendant Aetna, Inc.
`
`(hereinafter referred to as "Aetna") was a corporation whose headquarters are located at 151
`
`Farmington Avenue, Hartford, Connecticut, which conducted and continues to conduct significant
`
`business in the State of New Jersey.
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 2 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 8 of 17 PageID: 13
`
`3.
`
`At all times relevant, upon information and belief, fictitious Defendants John Does
`
`1-10, Jane Does 1-10 and ABC Corporations 1-10, are yet to be identified entities who directly
`
`and proximately caused damages to Plaintiff.
`
`JURISDICTION AND VENUE
`
`4.
`
`Plaintiffs office is located in Passaic County, New Jersey, and all medical services
`
`which are the subject matter of this action were rendered in Bergen Cowry, New Jersey.
`
`5.
`
`Patient, "MJ" herein identified only by Aetna Identification Number W214815125
`
`(hereinafter referred to as the "Patient"), received medical benefits through Defendant Aetna.
`
`6.
`
`Upon information and belief, at all relevant times, the Patient lived in Essex
`
`County, New Jersey.
`
`7.
`
`Plaintiff is proceeding on their own individual claims concerning medical services
`
`provided to the Patient.
`
`8.
`
`This matter is properly venued in State Court. None of Plaintiff's claims, as detailed
`
`infra, are governed by federal law, including the Employee Retirement Income Security Act
`
`("ERISA"). See, Pascack Valley Hosp. v. Local 464A UFCW Welfare Reimbursement Plan, 388
`
`F. 3d 393, 403-4 (3d Cir. 2004). (medical provider's claims not preempted by ERISA where (1)
`
`the medical provider's claims arose from a contract independent of the ERISA plan; (2) the patients
`
`were not parties to the contract between the provider and insurer; and (3) the dispute was limited
`
`to the amount of the payment, not the right to be paid.)
`
`9.
`
`The amount in controversy is at least $143,009.67.
`
`10.
`
`For all the reasons stated above, this Court has jurisdiction over this matter and,
`
`further, it is the proper venue for this matter to be heard.
`
`2
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 3 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 9 of 17 PageID: 14
`
`FACTUAL BACKGROUND
`
`1 1.
`
`This dispute arises out of the Defendants' refusal to pay Plaintiff the money to
`
`which Plaintiff is entitled for providing necessary medical services to the Patient.
`
`12.
`
`At all relevant times, Plaintiff was a non-participating or out-of-network provider
`
`that rendered medically necessary services to the Patient.
`
`13. On July 19, 2017 the Patient presented to the St. Joseph's Regional Medical Center
`
`(hereinafter referred to as the "Hospital"), where Dr. Peter DeNoble (hereinafter "Dr. DeNoble"),
`
`performed medically necessary services, including: left distal humerus open reduction internal
`
`fixation with olecranon osteotomy; left elbow ulnar nerve transposition; and use and interpretation
`
`of intraoperative fluoroscopy.
`
`14.
`
`Dr. DeNoble is a Board-Certified Orthopaedic Surgeon who is employed and/or
`
`contracted by the Plaintiff.
`
`15.
`
`Plaintiff, as part of its normal business practice, obtained authorization (reference
`
`number 3306754517) for the medically necessary treatment of the Patient. This authorization is
`
`also applicable to all physicians, including Dr. DeNoble, who is employed and/or contracted by
`
`the Plaintiff
`
`16.
`
`Primary surgery, on July 19, 2017, was performed by Dr. DeNoble.
`
`1 7.
`
`Dr. DeNoble was assisted by Erin Simon, PA, who is employed and/or contracted
`
`by Plaintiff.
`
`18.
`
`Plaintiff billed Defendant Aetna for the primary surgeon charges a total of
`
`$71,985.00.
`
`19.
`
`Plaintiff billed Defendant Aetna for the assistant charges a total of $71,985.00.
`
`3
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 4 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 10 of 17 PageID: 15
`
`20.
`
`The total billed charges of $143,970.00 for this medically necessary treatment
`
`represents normal and reasonable charges for the complex procedures performed by a Board-
`
`Certified Orthopaedic Surgeon practicing in New Jersey, with an assistant.
`
`21.
`
`Defendants paid a total of $960.33 toward these reasonable charges, leaving a
`
`balance due on this bill of approximately $143,009.67.
`
`22.
`
`While Defendants were aware that Plaintiff was an out-of-network provider,
`
`Defendants never disclosed that it did not intend to pay the fair and reasonable value for said
`
`services. To the contrary, by issuing an authorization number for the services, Defendants
`
`accepted and approved the medically necessary services provided by Plaintiff, with the explicit
`
`knowledge that Defendants never intended to pay the amounts they were obligated to pay.
`
`FIRST COUNT
`(Breach of Contract)
`
`23.
`
`Plaintiff repeats, reiterates and re-alleges each and every allegation set forth in
`
`paragraphs "1" through "22" of this Complaint with the same force and effect as if fully set forth
`
`herein at length.
`
`24.
`
`Plaintiff hereby alleges that an implied in-fact contract has been created through
`
`Defendants' course of conduct and interaction with Plaintiff (hereinafter, the "Contract").
`
`25. By authorizing the surgery, Defendants agreed to pay the fair and reasonable rates
`
`for the medical services provided by Plaintiff and Plaintiff performed said services based upon
`
`those terms.
`
`26.
`
`This implied Contract indicated that Plaintiff would be paid by Defendants a fair
`
`and reasonable amount for the highly-skilled services provided by the Plaintiff.
`
`27.
`
`However, Plaintiff was paid a mere $960.33 of the fair and reasonable amount of
`
`$143,009.67 for the highly-skilled services provided to the Patient.
`
`4
`
`

`

`BER-L-007526-21 1 1/16/2021 12:02:20 PM Pg 5 of 7 Trans ID: LUV2U212i5(5b/bii
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 11 of 17 PageID: 16
`
`28.
`
`Plaintiff has suffered significant damages as a result of Defendants' failure to pay
`
`the fair and reasonable value for the services.
`
`29. As a direct result of Defendants' breach of the Contract, Plaintiff has been damaged
`
`in an amount to be determined at trial, but not less than $143,009.67, plus interest, costs, and
`
`attorneys' fees.
`
`SECOND COUNT
`(Promissory Estoppel)
`
`30.
`
`Plaintiff repeats, reiterates and re-alleges each and every allegation set forth in
`
`paragraphs "1" through "29" of this Complaint with the same force and effect as if fully set forth
`
`herein at length.
`
`31.
`
`By providing a pre-surgery authorization to Plaintiff, Defendants promised that
`
`Plaintiff would be paid for its services at a fair and reasonable rate.
`
`32.
`
`Plaintiff relied upon this promise to its detriment by spending valuable time,
`
`resources, and energy in providing medical services to the Patient.
`
`33.
`
`As a direct result of Defendants' refusal to pay Plaintiff the fair and reasonable
`
`value for the services Plaintiff provided at the behest of Defendant, Plaintiff has been damaged in
`
`an amount to be determined at trial, but not less than $143,009.67, plus interest, costs, and
`
`attorneys' fees.
`
`THIRD COUNT
`(Account Stated)
`
`34.
`
`Plaintiff repeats, reiterates and re-alleges each and every allegation set forth in
`
`paragraphs "1" through "33" of this Complaint with the same force and effect as if fully set forth
`
`herein at length.
`
`5
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 6 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 12 of 17 PageID: 17
`
`35.
`
`After providing the medical services, which were authorized by Defendants,
`
`Plaintiff submitted bills and requests for payment to Defendants in the sum total of $143,970.00.
`
`36.
`
`To date, Defendants have acknowledged receipt of the bills, and have paid a mere
`
`$960.33 towards the invoices, but have not objected, in any manner, to the billed amounts,
`
`including, inter alia, the amount billed or to the services provided.
`
`37.
`
`Plaintiff has suffered significant damages as a result of Defendants' actions.
`
`38.
`
`As a direct result of Defendants' refusal to pay Plaintiff for the medical services
`
`provided and billed to Defendants, who acknowledged receipt without objection, Plaintiff has been
`
`damaged in an amount to be determined at trial, but not less than $143,009.67 plus interest, costs,
`
`and attorneys' fees.
`
`WHEREFORE, Plaintiff respectfully demands judgment against Defendants:
`
`1. As and for its First cause of action, for breach of an implied contract in an amount to be
`
`determined at trial, but not less than $143,009.67, along with its reasonable attorneys' fees, interest,
`
`costs and expenses; and
`
`2. As and for its Second cause of action under the theory of promissory estoppel in an
`
`amount to be determined at trial, but not less than $143,009.67, along with its reasonable attorneys'
`
`fees, interest, costs and expenses; and
`
`3. As and for its Third cause of action for an account stated, in an amount to be determined
`
`at trial, but not less than $143,009.67, along with its reasonable attorneys' fees, interest, costs and
`
`expenses; and
`
`4. Along with such other and further relief to plaintiff as this Court deems just, fair, and
`
`proper.
`
`6
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 7 of 7 Trans ID: LCV20212665758
`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 13 of 17 PageID: 18
`
`JURY DEMAND
`
`Pursuant to R. 4:35-1, plaintiff hereby demands a trial by jury as to all counts.
`
`DESIGNATION OF TRIAL COUNSEL
`
`Pursuant to R. 4:25-4, Dara J. Lawall, Esquire is hereby designated as trial counsel.
`
`CERTIFICATION
`
`I hereby certify that pursuant to R. 4:5-1 that the matter in controversy is not the subject of
`
`any other action pending in any Court or of a pending arbitration proceeding related to claims
`
`arising from medical services provided from Plaintiff to the Patient. No such action or arbitration
`
`proceeding is contemplated by plaintiff at this time.
`
`LA WALL & MITCHELL, LLC
`Attorneys for Plaintiff
`
`BY: /s/ jCi;),€4. 7.2ratee
`Dara J. Lawall, Esquire
`
`Dated: November 8, 2021
`
`7
`
`

`

`Civil Case Information Statement
`
`Case Details: BERGEN | Civil Part Docket# L-007526-21
`
`Case Caption: ADVANCED ORTHOPEDICS & HAND S
`VS AETNA, INC.
`Case Initiation Date: 11/16/2021
`Attorney Name: DARA J LAWALL
`Firm Name: LAWALL & MITCHELL
`Address: 55 MADISON AVE STE 400
`MORRISTOWN NJ 07960
`Phone: 9732853280
`Name of Party: PLAINTIFF : Advanced Orthopedics & Hand
`Su
`Name of Defendant’s Primary Insurance Company
`(if known): None
`
`Case Type: CONTRACT/COMMERCIAL TRANSACTION
`Document Type: Complaint with Jury Demand
`Jury Demand: YES - 12 JURORS
`Is this a professional malpractice case? NO
`Related cases pending: NO
`If yes, list docket numbers:
`Do you anticipate adding any parties (arising out of same
`transaction or occurrence)? NO
`
`Are sexual abuse claims alleged by: Advanced Orthopedics &
`Hand Su? NO
`
`THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
`CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
`
`Do parties have a current, past, or recurrent relationship? NO
`If yes, is that relationship:
`Does the statute governing this case provide for payment of fees by the losing party? NO
`Use this space to alert the court to any special case characteristics that may warrant individual
`management or accelerated disposition:
`
`Do you or your client need any disability accommodations? NO
`If yes, please identify the requested accommodation:
`
`Will an interpreter be needed? NO
`If yes, for what language:
`
`Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
`
`I certify that confidential personal identifiers have been redacted from documents now submitted to the
`court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
`
`11/16/2021
`Dated
`
`/s/ DARA J LAWALL
`Signed
`
`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 1 of 2 Trans ID: LCV20212665758
`
`

`

`BER-L-007526-21 11/16/2021 12:02:20 PM Pg 2 of 2 Trans ID: LCV20212665758
`
`

`

`Case 2:21-cv-20756 Document 1-1 Filed 12/29/21 Page 16 of 17 PageID: 21
`BER L 007526-21 11/17/2021 4:36:22 AM Pg 1 of 1 Trans ID: L0V20212672197
`
`BERGEN COUNTY COURTHOUSE
`SUPERIOR COURT LAW DIV
`BERGEN COUNTY JUSTICE CTR RN 415
`NJ 07601-7680
`HACKENSACK
`
`COURT TELEPHONE NO. (201) 221-0700
`COURT HOURS 8:30 AM - 4:30 PM
`
`TRACK ASSIGNMENT NOTICE
`
`DATE: NOVEMBER 16, 2021
`ADVANCED ORTHOPEDICS & HAND S VS AETNA, INC.
`RE:
`DOCKET: BER L -007526 21
`
`THE ABOVE CASE HAS BEEN ASSIGNED TO: TRACK 2.
`
`DISCOVERY IS 300 DAYS AND RUNS FROM THE FIRST ANSWER OR 90, DAYS
`FROM SERVICE ON THE FIRST DEFENDANT, WHICHEVER COMES FIRST.
`
`THE PRETRIAL JUDGE ASSIGNED IS: HON MARY F. THURBER
`
`IF YOU HAVE ANY QUESTIONS, CONTACT TEAM
`AT: (201) 527-2600.
`
`002
`
`IF YOU BELIEVE THAT THE TRACK IS INAPPROPRIATE YOU MUST FILE A
`CERTIFICATION OF GOOD CAUSE WITHIN 30 DAYS OF THE FILING OF YOUR PLEADING.
`PLAINTIFF MUST SERVE COPIES OF THIS FORM ON ALL OTHER PARTIES IN ACCORDANCE
`WITH R.4:5A-2.
`
`ATTENTION:
`
`ATT: DARA J. LAWALL
`LAWALL & MITCHELL
`55 MADISON AVE
`STE 400
`MORRISTOWN
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`NJ 07960
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`ECOURTS
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`BER-L-007526-21 12/13/2021 1:49:42 PM Pg 1 of 1 Trans ID: LCV20212932538
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