Motion to Stay Proceedings in Melograno Angela Vs Veloso Carlos| Trellis.Law

On January 19, 2022 a Motion,Ex Parte was filed involving a dispute between Angela Melograno, and Carlos Veloso, Geico Insurance Company, John Does, Kidsco, Prime Property And Casualty, Unity Transportation, Llc, for Auto Negligence-Personal Injury (Non-Verbal Threshold) in the District Court of Essex County.

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ESX-L-000407-22 10/26/2023 5:23:21PM Pglof2 Trans ID: LCV20233224503

LAW OFFICES OF THOMAS J. WAGNER, LLC
By: THOMAS J. WAGNER, ESQUIRE
AMY L. WYNKOOP, ESQUIRE
Attorney LD. Nos.: 047921988/029792008 Attorneys for Defendants, Carlos
8 Penn Center, 6" Floor Veloso and Unity Transportation,
1628 John F. Kennedy Boulevard
LLC
Philadelphia, PA 19103
P: 215-790-0761
F: 215-790-0762

ANGELA MELOGRANO, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v DOCKET NO.: ESX-L-407-22

CARLOS VELOSO, UNITY CIVIL ACTION
TRANSPORTATION, LLC (its servants,
agents, and/or employees), DEFENDANTS CARLOS VELOSO
AND UNITY TRANSPORTATION,
Defendants. LLC’S CROSS MOTION TO STAY
PIP SUBROGATION ACTION AND
RESPONSE TO GEICO AND GEICO
A/S/O0 ANGELA MELOGRANO’S
MOTION TO CONSOLIDATE

GEICO and GEICO a/s/o Angela Melograno, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

¥. DOCKET NO.: ESX-L-4357-23

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC, PRIME
PROPERTY & CASUALTY INSURANCE
INC., et al.,

Defendants.

TO Tony F. LaRocca, Esquire
Law Offices of Feeley & LaRocea, LLC
76 South Orange Avenue, Suite 211
South Orange, NJ 07079
E: tlaroccal 7@gmail.com
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TO William Hahn, Esquire
Tango, Dickinson, Lorenzo, McDermott & McGee, LLP
75 Main Street P.O. Box 192
Millburn, New Jersey 07041

TO Susan A. Lawless
Florio, Perrucci, Steinhardt, Capelli, Tipton & Taylor LLC
60 West Broad St., Suite 201
Bethlehem, PA 18018
E: Slawless@floriolaw.com

PLEASE TAKE NOTICE that on November 3, 2023, at 9:00 a.m. or as soon thereafter

as counsel may be heard, the undersigned, attorneys for Defendants Carlos Veloso and Unity

Transportation, LLC, shall move before the Essex County Superior Court for an Order staying

the PIP subrogation action under docket number ESX-L-4357-23 until Plaintiff Agela

Melograno’s bodily injury claim is resolved pursuant to N.J.S.A. 39:6A-9.1(b). Further,

Defendants object to the consolidation of the two cases.

A proposed Order is attached.

Defendants will rely on the attached Certification of Counsel with Exhibits. A proposed

form of Order for the same is attached pursuant to R. 1:6-2.

Oral Argument is requested.

Docket No.: ESX-L-407-22
DISCOVERY END DATE NOVEMBER 27, 2023
ARBITRATION DATE: MARCH 26, 2024
TRIAL DATE: NOT AFFIXED

LAW OFFICES OF THOMAS J. WAGNER, LLC

mw A THOMAS J. WAGNER, ESQUIRE
AMY L. WYNKOOP, ESQUIRE
Attorneys for Defendants Carlos Veloso
and Unity Transportation, LLC
Dated: 10/26/2023
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ANGELA MELOGRANO, | SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v. DOCKET NO.: ESX-L-407-22

CARLOS VELOSO, UNITY CIVIL ACTION
TRANSPORTATION, LLC (its servants,
agents, and/or employees),

Defendants. PROPOSED ORDER

GEICO and GEICO a/s/o Angela Mclograno, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

Vv. DOCKET NO.: ESX-L-4357-23

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC, PRIME
PROPERTY & CASUALTY INSURANCE
INC., ct al.,

Defendants.

This matter having been opened to the Court by the GEICO and GEICO, a/s/o Angela

Melograno, through their counsel, Tango, Dickinson, Lorenzo, McDermott & McGee, LLP's

Motion for Consolidation and Defendants Carlos Veloso and Unity Transportation, LLC,

through their counsel, the Law Offices of Thomas J. Wagner, LLC, response thereto and Cross-

Motion to stay the PIP Subrogation action, and the Court having considered the moving papers,

and for good cause shown:

IT IS on this day of . 2023;
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ORDERED that Plaintiff, GEICO and GEICO a/s/o Angela Mclograno's Motion to

Consolidate is DENIED.

IT IS FURTHER ORDERED that Defendants' Cross-Motion to Stay the PIP

Subrogation Action (Docket No.: ESX-L-4357-23) is HEREBY GRANTED pursuant to

N.J.S.A. 39:6A-9.1(b).

IT IS FURTHER ORDERED that a copy of this Order shall be deemed served upon all

parties within days of receipt and in accordance with R. 1:5-l(a).

IS.C

[ ] Opposed
[ ] Unopposed
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LAW OFFICES OF THOMAS J. WAGNER, LLC
By: THOMAS J. WAGNER, ESQUIRE
AMY L. WYNKOOP, ESQUIRE
Attorney E.D. Nos.: 047921988/029792008 Attorneys for Defendants, Carlos
8 Penn Center, 6 Floor Veloso and Unity Transportation,
1628 John F. Kennedy Boulevard
LEC
Philadelphia, PA 19103
P: 215-790-0761
F: 215-790-0762

ANGELA MELOGRANO, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v. DOCKET NO.: ESX-L-407-22

GEICO and GEICO a/s/o Angela Melograno, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v. DOCKET NO.: ESX-L-4357-23

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC, PRIME
PROPERTY & CASUALTY INSURANCE
INC., et al.,

Defendants.

1, Amy L. Wynkoop, Esquire, am a Partner in the Law Offices of Thomas J. Wagner,

LLC, and the attorney for Defendants, Carlos Veloso (“Mr. Veloso”) and Unity Transportation,

LLC, (“Unity”) (collectively referred to as “Defendants”) in the personal injury suit initiated by

Plaintiff Angela Melograno (Docket No.: ESX-L-407-22). [ am fully familiar with the matter set
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forth in the personal injury action and make this certification in Support of Defendants’

Opposition to Plaintiff, GEICO and GEICO a/s/o Angela Melograno’s (“GEICO”) Motion to

Consolidate and in support of Defendants’ Cross Motion for an Order pursuant to N.LS.A.

39:6A-9.1(b) to stay the PIP Subrogation Action (Docket No.: ESX-L-4357-23) until completion

of Plaintiff Angela Melograno’s personal injury action.

1 This action arises from a motor vehicle accident that occurred on or about July 12,

2021, at the intersection of Franklin Avenue and Belleville Avenue, in Belleville, Essex County,

NJ.

2. On or about January 19, 2022, Plaintiff, Angela Melograno initiated a personal

injury suit under Docket No.: ESX-L-407-22 (“PI Action”). She filed a Complaint alleging that

due to the July 12, 2021 motor vehicle accident, she sustained “serious, significant and

permanent injuries and disabilities,” requiring medical treatment, and claimed damages for pain

and suffering, medical care, and lost wages. (A true and correct copy of Ms. Melograno’s

Complaint is attached as Exhibit “A”).

3 The only remaining Defendants are Mr. Veloso and Unity ‘Transportation, LLC in

the PI Action.

4 There was an issue regarding insurance coverage in the underlying PI Action, and

Ms. Melograno’s UIM/UM carrier, GEICO, was named as a Defendant.

5 Pursuant to GEICO’s Motion for Summary Judgment alleging that there was

insurance available to Defendants Mr. Veloso and Unity Transportation, LLC, GEICO was

dismissed as a party on July 13, 2023 in the PI Action. (A copy of the Order is attached as

Exhibit “B”).
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6 It appears from the docket in the PIP Subrogation action (Docket No.: ESX-L-

4357-23)(“Subro Action”), that GEICO filed a Complaint seeking recovery of PIP and Property

benefits paid to GEICO’s insured, Ms. Melograno.

7 The deadline for depositions has already expired in the PI Action. (A true and

correct copy of the most recent Case Management Order is attached as Exhibit “C”).

8 The deadline for Plaintiff's expert reports has already expired in the PI Action.

(Sce Exhibit “C”).

9 The deadline for Defendants’ expert reports is fast approaching on November 12,

2023 in the PI Action. (See Exhibit “C”).

10. Discovery in the PI Action closes on November 27, 2023. (See Exhibit “C”).

ll Arbitration in the PI Action has been scheduled for March 26, 2024.

12. Although nearing the end of litigation, the PI Action is ongoing.

13 On October 11, 2023, Plaintiff GEICO in the Subro Action seeks to consolidate

the two cases despite the expiration of deadlines and fast approaching discovery end date of the

PI Action allowing no time for discovery in the Subro Action and/or delaying the PI Action to

allow for additional discovery.

14. Defendants Mr. Veloso and Unity Transportation in the PI Action submit the

instant opposition to the consolidation of the same and submit that the Subro action should be

stayed pending resolution of Plaintiff Ms. Melograno’s personal injury claim pursuant to

N.J.S.A. 39:6A-9.1(b).
15. It is well established that any potential recovery by a PIP carrier can only be made

after satisfaction of the insured’s personal injury action. N.J.S.A. 39:6A-9.1(b).
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16. Rule 4:38-1 governs consolidation: ‘Two cases may be consolidated if they

involve common questions of law and fact arising out of the same transaction or series of

transactions. R. 4:38-1(a).

1%, The decision to consolidate is at the discretion of the trial court and will not be

overturned absent a determination it was manifestly unjust. Kasclaan & D’Angelo Assocs. v.

Soffian, 675 A.2d 705 (App. Div. 1996); Gittleman v. Cent. Jersey Bank & Trust Co., 246 A.2d

757 (App. Div. 1967); and Union County Imp. Authority v. Artaki, LLC, 920 A.2d 125 (App.

Div. 2007). A consolidation request can be denied if consolidation will cause delay and/or

interfere with discovery or trial dates. Robert T. Winzinger, Inc. v. Brennan Bros., Inc., 465

A.2d 579 (Law Div. 1983)(requiring the consolidation rule be interpreted along with R. 1:1-2

which requires the rules to be ‘construed to secure a just determination, simplicity in procedure,

fairness in administration and the elimination of unjustifiable expense and delay’). Defendants

submit that this is the case here.

WHEREFORE, Defendants Carlos Veloso and Unity Transportation respectfully request

that GEICO’s Motion to Consolidate the PI Action and the Subro Action be denied and the

Subro Action be stayed until completion of Ms. Melograno’s personal injury claim.

I certify that the foregoing statements made by me are true. | am aware that if any of the

foregoing statements made by me are willfully false, I am subject to punishment.

LAW OFFICES OF THOMAS J. WAGNER, LLC

AMY L. WYNKOOP, ESQUIRE
Attorneys for Defendants Carlos Veloso
and Unity Transportation, LLC
Dated: 10/26/2023
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LAW OFFICES OF THOMAS J. WAGNER, LLC
By: THOMAS J. WAGNER, ESQUIRE
Attorneys for Defendants, Carlos
AMY L. WYNKOOP, ESQUIRE
Attorney I.D. Nos.: 047921988/029792008 Veloso and Unity Transportation,
8 Penn Center, 6" Floor LLC
1628 John F. Kennedy Boulevard
Philadelphia, PA 19103
P: 215-790-0761
F: 215-790-0762

ANGELA MELOGRANO, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

Vv DOCKET NO.: ESX-L-407-22

CARLOS VELOSO, UNITY CIVIL ACTION
TRANSPORTATION, LLC (its servants,
agents, and/or employees), CERTIFICATE OF SERVICE

Defendants.

GEICO and GEICO a/s/o Angela Melograno, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v DOCKET NO.: ESX-L-4357-23

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC, PRIME
PROPERTY & CASUALTY INSURANCE
INC., et al.,

Defendants.

The undersigned hereby certifies that a true and correct copy of Defendants Cross Motion

and Opposition was served on all counsel of record via electronic filing and electronic mail.

LAW OFFICES OF THOMAS J. WAGNER, LLC

BY:
THOMAS J. WI SNE! , ESQUIRE
AMY L. WYNKOOP, ESQUIRE
Attorneys for Defendants Carlos Veloso
and Unity Transportation, LLC
Dated: 10/26/2023

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EXHIBIT “A”
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LAW OFFICES OF FEELEY & LAROCCA, LLC
Tony F. LaRocea, Esq.
76 South Orange Avenue, Suite 211
South Orange, New Jersey 07079
(973)821-5360
FAX: (973)821-5359
Attorneys for Plaintiff
Attorney ID No.: 009101988
ae sense neers eee ccna neeeeneeeneaeceeeweeemrueg

ANGELA MELOGRANO SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
Plaintiff(s),

vs. DOCKET NO.:

CARLOS VELOSO, UNITY CIVIL ACTION
TRANSPORTATION, LLC. {its
servants, agents and/or employees),
PRIME PROPERTY AND CASUALTY | COMPLAINT AND JURY DEMAND
INSURANCE INC., (its servants, agents
and/or employees), KIDSCO {its
servants, agents and/or employees),
JOHN DOES (fictitious names intending
to designate the owners and/or operators
of motor vehicles contributing to this
accident), GEICO Insurance Company

Defendant(s).
ween ete ne ene eee

Plaintiff(s), Angela Melograno, residing at 35 Parkside Drive, Belleville, NJ, by way of

Complaint against the defendants says:

FIRST COUNT

1 On or about July 12, 2021, at approximately 2:28 P.M., Plaintiff, Angela

Melograno, was properly operating her vehicle and stopped at a red traffic signal on Belleville

Avenue at its intersections with Franklin Avenue in Belleville, Essex County, New Jersey, At

that time and place, a vehicle operated by Defendant, Carlos Veloso, owned by Defendant, Unity
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Transportation, LLC and insured by Defendant, Prime Property and Casualty Insurance Inc.,

negligently struck the rear of Plaintiff, Angela Melograno’s stopped vehicle.

2 At all relevant times, the Defendants, Carlos Veloso, Unity Transportation, LLC.

{its servants, agents and/or employees), Prime Property and Casualty Insurance Inc., (its

servants, agents and/or employees), KIDSCO (its servants, agents and/or employees) and John

Does (fictitious name as described above), were negligent and careless in the ownership,

operation, maintenance, entrustinent, inspection, repair, upkeep, control and inspection of their

motor vehicle and contributed to this accident.

3 At all relevant times, the Defendants, Carlos Veloso, Unity Transportation, LLC.

(its servants, agents and/or employees), Prime Property and Casualty Insurance Inc., (its

servants, agents and/or employees), KIDSCO (its servants, agents and/or employees) and John

Does (fictitious name as described above), were negligent and careless and/or palpably

unreasonable in the ownership, operation, maintenance, entrustment, inspection, repair, upkeep,

control and inspection of their motor vehicle and contributed to this accident.

4 At all relevant times, the Defendants, Carlos Veloso, Unity Transportation, LLC.

(its servants, agents and/or employees), Prime Property and Casualty Insurance Inc., (its

servants, agents and/or employees), KIDSCO (its servants, agents and/or employees) and John

Does (fictitious name as described above), failed to yield to other mototists on the roadway,

failed to obey traffic control devices, failed to keep their car under control and failed to operate

their motor vehicle(s) with due regard to other motorists on the roadway and otherwise caused

the collision wherein the Plaintiff was injured.
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5 Defendant, Prime Property and Casualty Insurance Company on information and

belief was the insurance carrier for Defendant, Carlos Veloso and/or Unity Transportation LLC

and has negligently and/or wrongfully denied coverage.

6 At all relevant times, the Defendants, Carlos Veloso, Unity ‘Transportation, LLC.

(its servants, agents and/or employees), Prime Property and Casualty Insurance Inc., (its

servants, agents and/or employees), KIDSCO (its servants, agents and/or employees) and John

Does (fictitious name as described above) were negligent and careless and/or palpably

unreasonable and the Defendants, Carlos Veloso, Unity Transportation, LLC. (its servants,

agents and/or employees), Prime Property and Casualty Insurance Inc., (its servants, agents

and/or employees), KIDSCO (its servants, agents and/or employees) and John Does (fictitious

name as described above) were the masters or principals of these servants, agents or employees,

and are vicariously responsible for the acts of these servants, agents and employees under the

theory of respondent superior and also responsible for negligently hiring and retaining said

person(s).

7 As a direct and proximate result of the negligence, carelessness and/or palpably

unreasonable action and other improper conduct of the defendants listed in this Count, the

plaintifi{s) sustained serious, significant and permanent injuries and disabilities, and has been

unable to pursue his/her usual pursuits and occupations, has experienced a diminished quality of

life, incurred medical bills, lost wages and has otherwise sustained a serious significant and

functional disability and sustained serious and significant injuries including but not limited to a

fracture, a permanent loss of use and a permanent consequential limitation of use of a body

function or system and has otherwise been medically unable to perform substantially all of

his/her usual and customary daily activities for more than 90 out of the first 180 days following
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this accident and has otherwise satisfied the requirements of N,J.S.A. 39:6A-8, and/or N.J.S.A.

Title 59, Tort Claims Act.

WHEREFORE, Plaintiff, Angela Melograno, demands judgment on this Count against

the Defendants, Carlos Veloso, Unity Transportation, LLC. (its servants, agents and/or

employees), Prime Property and Casualty Insurance Inc., (its servants, agents and/or employees),

KIDSCO (its servants, agents and/or employees) and JOHN DOES (fictitious name as described

above) and each of them as aforesaid, individually, jointly, severally or in the alternative, for

damages together with interests and costs of suit.

SECOND COUNT

1 The Plaintiff repeats each and every allegation of the First Count as if set forth at

length herein.

2. On or about July 12, 2021, at approximately 2:28 P.M., Plaintiff, Angela

Melograno, was properly operating her vehicle and stopped at a red traffic signal on Belleville

Avenue at its intersections with Franklin Avenue in Belleville, Essex County, New Jersey. At

that time and place, a vehicle operated by Defendant, Carlos Veloso, owned by Defendant, Unity

Transportation, LLC and insured by Defendant, Prime Property and Casualty Insurance Inc.,

negligently struck the rear of Plaintiff, Angela Melograno’s stopped vehicle,

3 At all relevant time the Plaintiff, Angela Melograno, was insured under a private

passenger auto policy with Personal Injury Protection benefits and Uninsured/Underinsured

coverage through Geico Insurance Company and is entitled to all Personal Injury Protection

Benefits and Uninsured, Underinsured Motorist coverage provided in her automobile insurance

policy.
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4 WHEREFORE, Plaintiffs demand judgment on this Count against the Defendants

listed in this Count for damages together with attorney fees and costs.

JURY DEMAND

Plaintiff(s) hereby demands a trial by jury of six (6) persons as to all issues contained

herein.

DESIGNATION OF TRIAL COUNSEL

Pursuant to R. 4:25-4, Tony F. La Rocca, Esg., is hereby designated as trial counsel for

the Plaintiff(s) in the above matter.

CERTIFICATION OF NO OTHER ACTIONS

Pursuant to R. 4:5-1, it is hereby stated that the matter in controversy is not the subject of

any other action pending in any other Court or of a pending arbitration proceeding to the best of

our knowledge or belief. Also, to the best of our belicf, no other action or arbitration proceeding

is contemplated. Further, other than the parties set forth in this pleading, we know of no other

parties that should be joined in the above action.

we
LAW OFFIC FEERLEY & LAROCCA, LLC.

BY: 2 COCO
Tony F. La Rocea, Esq.
Attorney for Plaintiff(s)

Dated: January 18, 2022
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Civil Case Information Statement

Case Details: ESSEX | Civil Part Docket# L-000407-22

Case Caption: MELOGRANO ANGELA VS VELOSO. Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (NON-
CARLOS, VERBAL THRESHOLD)
Case Initiation Date: 01/19/2022 Document Type: Complaint with Jury Demand
Attorney Name: TONY F LA ROCCA Jury Demand: YES - 6 JURORS:
Firm Name: FEELEY & LAROCCA, LLC Is this a professional malpractice case? NO
Address: 76 SOUTH ORANGE AVE STE 211 Related cases pending: NO
SOUTH ORANGE NJ 07079 If yes, list docket numbers:
Phone: 9738215360 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : MELOGRANO, ANGELA transaction or occurrence)? NO
Name of Defendant's Primary Insurance Company
(if known): None Are sexual abuse claims alleged by: ANGELA MELOGRANO? 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

| 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)

01/19/2022 Js/ TONY F LA ROCCA
Dated Signed

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EXHIBIT “B”
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ESX-L-000407-22 07/13/2023 Pg 1of2 Trans ID: LCV20232189640

ve FRILED
Law Ottices of Leslie A. DeTorres sur’ 1 4 2028 Het

300 Executive Drive, Suite 240
West Orange, NJ 07052 tehlon. Stephan t. Petrillo, £80.
973-766-9532
By: Brian McAteer, Esq. - Attorney ID# 275092018
Attorney for Defendant,
GEICO Insurance Company
SUPERIOR COURT OF NEW JERSEY
ANGELA MELOGRANO, LAW DIVISION: ESSEX COUNTY
DOCKET NO: ESX-L-407-22
Plaintiffs,
Civil Action
vs.
ORDER GRANTING SUMMARY
CARLOS VELOSO, UNITY JUDGMENT TO GEICO INSURANCE
TRANSPORTATION, LLC. (its servants, COMPANY
agents and/or employees), PRIME
PROPERTY AND CASUALTY
INSURANCE INC.,, (its servants, agents
and/or employees), KIDSCO (its servants,
agents and/or employees), JOHN DOES
(fictitious names intending to deisgnate the
owners and/or operators of motor vehicles
contributing to this accident), GEICO
Insurance Company,

Defendants.

THIS MATTER being opened to the court by the Law Offices of Leslie A. DeTorres,

attorneys for defendant GEICO, and the court having considered the moving papers, such

papers as may have been filed in opposition, and the oral argument of counsel, if any, and with

good cause being shown;

IT IS on this / 4 day of HN > 20 2 alioreby

ORDERED that the plaintiff's Complaint and all crossclaims, if any, against defendant

GEICO, are hereby dismissed with prejudice.

ORDERED that the within Order shall be deemed automatically served upon all

parties simultaneously with its online posting in E-Courts in accordance with Rule 1:5-1(a).
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ESX-L-000407-22 07/13/2023 Pg2of2 Trans ID: plese he
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Opposed ~~Hon. Stephen L. Petrillo, J.S.C
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LAW OFFICES OF THOMAS J. WAGNER, LLC
By: THOMAS J. WAGNER, ESQUIRE
AMY L. WYNKOOP, ESQUIRE Attorneys for Defendants, Carlos
Attorney ID. Nos.: 047921988/029792008 Veloso and Unity Transportation,
8 Penn Center, 6 Floor LLC
1628 John F. Kennedy Boulevard
Philadelphia, PA 19103
P: 215-790-0761
F: 215-790-0762

ANGELA MELOGRANO, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

v. DOCKET NO.: ESX-L-407-22

CARLOS VELOSO, UNITY CIVIL ACTION
TRANSPORTATION, LLC (its servants,
agents, and/or employees), CERTIFICATE OF SERVICE

Defendants.

GEICO and GEICO a/s/o Angela Melograno, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: ESSEX COUNTY

¥: DOCKET NO.: ESX-L-4357-23

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC, PRIME
PROPERTY & CASUALTY INSURANCE
INC., et al.,

Defendants.

The undersigned hereby certifies that a true and correct copy of Defendants Cross Motion

and Opposition was served on all counsel of record via electronic filing and electronic mail.

LAW OFFICES OF THOMAS J. WAGNER, LLC

BY: AW aaa
THOMAS J. WAGNER, ESQUIRE
AMY L. WYNKOOP, ESQUIRE
Attorneys for Defendants Carlos Veloso
and Unity Transportation, LLC
Dated: 10/26/2023
ESX-L-000407-22 10/26/2023 5:23:21PM Pglof3 Trans ID: LCV20233224503

EXHIBIT “C”
ESX-L-000407-22 10/26/2023 5:23:21 PM Pg2of3 Trans ID: LCV20233224503
ESX-L-000407-22 08/25/2023 Pg1of2 Trans ID: LCV20232459246

FILED
August 25th, 2023
LAW OFFICES OF THOMAS J. WAGNER, LLC Honorable Stephen L. Petrillo,
By: THOMAS J. WAGNER, ESQUIRE JSC.
AMY L. WYNKOOP, ESQUIRE
Attorney ID. Nos.: 047921988/029792008 Attorneys for Defendants, Carlos
8 Penn Center, 6" Floor Veloso and Unity Transportation,
1628 John F. Kennedy Boulevard
LLC
Philadelphia, PA 19103
P: 215-790-0761
F: 215-790-0762

SUPERIOR COURT OF NEW JERSEY
ANGELA MELOGRANO
LAW DIVISION: ESSEX COUNTY
Plaintiff(s),
DOCKET NO. ESX-L-000407-22

CARLOS VELOSO, UNITY
TRANSPORTATION, LLC (its servants,
CIVIL ACTION
agents and/or employees), PRIME
PROPERTY AND CASUALTY
INSURANCE INC., (its servants, agents
and/or employees), KIDSCO (its servants,
agents and/or employees), JOHN DOES
(fictitious names intending to designate the
owners and/or operators of motor vehicles
contributing to this accident), GEICO PROPOSED ORDER
Insurance Company,
Defendant(s).

This matter having been opened to the Court by the Law Offices of Thomas J. Wagner,

LLC, attorneys for Defendants Carlos Veloso and Unity ‘Transportation, LLC, upon Defendants’

Motion to Extend the Discovery Deadline for a period of ninety (90) days and the Court having

considered the moving papers, and for good cause shown:

IT IS on this 25th day of August » 2023;

ORDERED that the discovery period in this matter is hereby extended until Monday,

November 27, 2023, pursuant to the following schedule:

(a) Any deposition(s) to take place by October 4, 2023;
ESX-L-000407-22 10/26/2023 5:23:21PM Pg3of3 Trans ID: LCV20233224503
ESX-L-000407-22 08/25/2023 Pg 2of2 Trans ID: LCV20232459246

(b) Plaintiff will serve all expert reports by October 12, 2023;

(d) Completion of Discovery by November 27, 2023.

IT IS FURTHER ORDERED that Plaintiff, Angela Melograno, will produce executed

Authorizations upon Defendants, Carlos Veloso and Unity Transportation, LLC, within twenty

(20) days ofthe docketing of this Order or risk sanctions upon further Motion to this Court.

Ss Leelee 2003-
;

IT IS FURTHER ORDERED that a copy of this Order shall be deemed served upon ail

parties in accordance with R. 1:5-1(a).

isi Stephen L. Petrillo
Honorable Stephen L. Petrillo, J.S.C.

Ci Opposed
[x] Unopposed

Case Info

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Stephen L Petrillo Track Judge’s New Case

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Document Filed Date

October 26, 2023

Case Filing Date

January 19, 2022

County

Parties

Angela Melograno Plaintiff
Brian J Mcateer Attorney for the Defendant
Carlos Veloso Defendant
Cynthia Andras Satter Attorney for the Defendant
Geico Insurance Company Defendant
John Does Defendant
Kidsco Defendant
Prime Property And Casualty Defendant
Susan A Lawless Attorney for the Defendant
Thomas J Wagner Attorney for the Defendant
Tony F La Rocca Attorney for the Plaintiff
Unity Transportation, Llc Defendant
WILLIAM HONAN Attorney

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Motion,Ex Parte: Melograno Angela Vs Veloso Carlos

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