Motion to Extend Discovery Cut-Off Date in Salas Rosario Vs Barr-Kramer Diane| Trellis.Law

On October 11, 2023 a Motion,Ex Parte was filed involving a dispute between Rosario Salas, and Diane C Barr-Kramer, for Auto Negligence-Personal Injury (Verbal Threshold) in the District Court of Essex County.

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ESX-L-001615-24 03/06/2024 11:36:17 AM Pg 1 of 3 Trans ID: LCV2024590259

Jenna K. Clemente, Esq.
NJ Attorney ID 275792018
HARDIN, KUNDLA, MCKEON & POLETTO
COUNSELLORS AT LAW
A PROFESSIONAL CORPORATION

673 MORRIS AVENUE

SPRINGFIELD, NEW JERSEY 07081
(973) 912-5222

Attorneys for Defendant, Diane C. Barr-Kramer

DIANE KRAMER, :
SUPERIOR COURT OF NEW JERSEY
Plaintiff, : LAW DIVISION: ESSEX COUNTY
Docket No. ESX-L-458-23
vs. :
Civil Action
WORLD SUBARU, LLC, 688 :
SHREWSBURY, LLC, CORPORATION
SERVICE COMPANY, ROSARIO SALAS, : NOTICE OF MOTION TO EXTEND
ALLSTATE NEW JERSEY PROPERTY DISCOVERY
AND CASUALTY INSURNACE COMPANY, :

Defendants. :

: SUPERIOR COURT OF NEW JERSEY
ROSARIO SALAS, LAW DIVISION: ESSEX COUNTY
: Docket No. ESX-L-1615-24
Plaintiff,
vs. : Civil Action

DIANE C. BARR-KRAMER, :

Defendants. :
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TO: Anneris V. Hernandez, Esq.
FREDSON STATMORE BITTERMAN, LLC
200 Broadacres Drive, Suite 180
Bloomfield, New Jersey 07003
Attorney for Plaintiff, Diane Kramer

Sander Budanitsk, Esq.
SANDER BUDANITSKY LLC
520 W 1st Ave
Roselle, New Jersey 07203
Attorney for Plaintiff, Rosario Salas

David Cramer, Esq.
WALSH PIZZI O'REILLY FALANGA LLP
15th Floor, Three Gateway Center
100 Mulberry St, Newark, NJ 07102
Attorney For Defendants, World Subaru, LLC and 688
Shrewsbury, LLC

Erica Tiffany Parkes, Esq.
LAW OFFICE OF LESLIE A. DETORRES
300 Executive Drive Suite 230
West Orange, New Jersey 07052
Attorney for Defendant, Rosario Salas

Michele Frances Benenato, Esq.
LAW OFFICES OF PAMELA D. HARGROVE
100 Walnut Avenue, Suite 602
Clark, New Jersey 07066
Attorney for Defendant, Allstate New Jersey Property and
Casualty Insurance Company

COUNSELOR:

PLEASE TAKE NOTICE that the undersigned attorneys for the

Defendant, Diane C. Barr-Kramer, shall apply to the Superior Court

of New Jersey, Law Division, Essex County, New Jersey, on March

28, 2024 at nine o'clock in the forenoon or as soon thereafter as

counsel may be heard, for an order extending discovery.

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We shall rely upon the attached Certified Statement in support

hereof.

Pursuant to R. 1:6-2(a), a copy of the proposed form of Order

is annexed hereto and the motion shall be deemed uncontested unless

responsive papers are timely filed and served stating with

particularity the basis of the opposition to the relief sought.

Pursuant to R. 1:6-2(d), the moving party waives oral argument

unless opposing papers are timely filed and served.

WE HEREBY CERTIFY that the original of the within Notice of

Motion has been filed with the Motions Clerk of Essex County and

a copy of same has been transmitted to all parties.

HARDIN, KUNDLA, MCKEON & POLETTO, PA
Attorneys for Defendant, Diane C.
Barr-Kramer

By:
Jenna K. Clemente, Esq.

DATED: March 6, 2024

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Jenna K. Clemente, Esq.
NJ Attorney ID 275792018
HARDIN, KUNDLA, MCKEON & POLETTO
COUNSELLORS AT LAW
A PROFESSIONAL CORPORATION
673 MORRIS AVENUE
SPRINGFIELD, NEW JERSEY 07081
(973) 912-5222

Attorneys for Defendant, Diane C. Barr-Kramer

:
DIANE KRAMER, SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: ESSEX COUNTY
Plaintiff, Docket No. ESX-L-458-23
:
vs. Civil Action
:
WORLD SUBARU, LLC, 688
SHREWSBURY, LLC, CORPORATION : ORDER
SERVICE COMPANY, ROSARIO
SALAS, ALLSTATE NEW JERSEY :
PROPERTY AND CASUALTY
INSURNACE COMPANY, :

Defendants. :

SUPERIOR COURT OF NEW JERSEY
ROSARIO SALAS, : LAW DIVISION: ESSEX COUNTY
Docket No. ESX-L-1615-24
Plaintiff, :
vs. Civil Action
:
DIANE C. BARR-KRAMER,
:
Defendants.
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This matter having been opened to the Court upon the application of

HARDIN, KUNDLA, MCKEON & POLETTO, PA, attorneys for Defendant, Diane C.

Barr-Kramer, for an Order extending the time for discovery pursuant to Rule

4:24-1 and the Court having considered the moving papers and for good cause

and exceptional circumstances shown;

IT IS on this day of , 2024,

ORDERED that the time for completion of discovery is hereby extended;

and it is further

ORDERED that the new discovery end date is October 30, 2024; and it

is further

ORDERED that the following discovery is to proceed in this discovery

extension period:

Discovery To Be Completed By:

Written Discovery April 30, 2024
Depositions June 30, 2024
Plaintiff Expert Report(s) July 15, 2024
Plaintiff IME August 31, 2024
Defendant Expert Report(s) October 15, 2024
Any remaining discovery October 30, 2024

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

counsel via electronic filing.
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, J.S.C.

___ Unopposed

___ Opposed
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Jenna K. Clemente, Esq.
NJ Attorney ID 275792018
HARDIN, KUNDLA, MCKEON & POLETTO
COUNSELLORS AT LAW
A PROFESSIONAL CORPORATION

673 MORRIS AVENUE

SPRINGFIELD, NEW JERSEY 07081
(973) 912-5222

Attorneys for Defendant, Diane C. Barr-Kramer

:
DIANE KRAMER, SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION: ESSEX COUNTY
Plaintiff, Docket No. ESX-L-458-23
:
vs. Civil Action
:
WORLD SUBARU, LLC, 688
SHREWSBURY, LLC, CORPORATION : CERTIFIED STATEMENT
SERVICE COMPANY, ROSARIO SALAS,
ALLSTATE NEW JERSEY PROPERTY :
AND CASUALTY INSURNACE COMPANY,
:
Defendants.

: SUPERIOR COURT OF NEW JERSEY
ROSARIO SALAS, LAW DIVISION: ESSEX COUNTY
: Docket No. ESX-L-1615-24
Plaintiff,
vs. : Civil Action

DIANE C. BARR-KRAMER, : CERTIFIED STATEMENT

Defendants. :
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Jenna K. Clemente, hereby certifies that:

1. I am an attorney at law of the State of New Jersey and

have been entrusted with the handling of the defense of the within

matter on behalf of Defendant, Diane C. Barr-Kramer.

2. This Certified Statement is made in support of

Defendant's motion to extend discovery.

3. In the Plaintiff Diane Kramer matter, a Consent Order

extending the time for discovery an additional sixty (60) days as

set forth in Rule 4:24-1(c) was consented to by all parties and

the discovery end date was previously extended to February 17,

2024. See Exhibit A.

4. In the Plaintiff Rosario Salas matter, the initial

discovery end date is October 30, 2024 and has not yet been subject

to any discovery extensions.

5. On February 23, 2024, the undersigned’s motion to

consolidate and transfer the Plaintiff Rosario Salas matter from

Union County to Essex County was granted. However, Judge Venable

declined the portion of the order regarding the discovery extension

and stated that the discovery end date shall be determined by the

trial judge. See Exhibit B.

6. The Plaintiff Rosario Salas matter was only officially

transferred and given an Essex County docket number on March 6,

2024. The instant motion was filed shortly thereafter.
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7. The matters have only just been consolidated and

discovery in the Salas matter has not yet been exchanged. While

the discovery end date expired in the Plaintiff Kramer matter on

February 17, 2024, the parties made a good faith attempt to extend

discovery prior to the expiration of the discovery period by

including the request in the motion to consolidate and transfer -

- however, that portion of the order was denied without prejudice

to permit the pre-trial judge the opportunity to set the discovery

end date. See Exhibit B.

8. An extension of the consolidated discovery end date is

sought in order to complete the discovery set forth below.

9. Good cause and exceptional circumstances exist as a

basis for this request.

10. Our system of justice favors the fair disposition of

cases on their merits. Viviano v. CBS, Inc., 101 N.J. 538, 547

(1986). Exceptional circumstances can arise where trial dates or

other litigation deadlines should be extended in the interest of

justice and to avoid punishing litigants unfairly. Leitner v. Toms

River Reg’l Sch., 392 N.J. Super. 80, 91-94 (App. Div. 2007).

11. In Vitti v. Brown, 359 N.J. Super. 40 (Law Div. 2003),

the Court established a four-part test for determining whether a

movant has shown “exceptional circumstances” for a discovery

extension requested after the discovery period has expired. A
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movant must show: (1) why discovery has not been completed within

time and counsel’s diligence in pursuing discovery during that

time; (2) the additional discovery or disclosure sought is

essential; (3) an explanation for counsel’s failure to request an

extension of the time for discovery within the original time

period; and (4) the circumstances presented were clearly beyond

control of the attorney and litigant seeking the extension of time.

Rivers v. LSC Partnership, 378 N.J. Super. 68, 79 (App. Div. 2005)

(citing Vitti, supra at 51).

12. Despite best efforts of counsel, discovery remains

incomplete.

13. As previously indicated, the Plaintiff Salas matter is

in the early stages of discovery. We have not yet exchanged

written discovery, conducted depositions, or exchanged expert

reports.

14. As of the filing of this application, the undersigned is

unaware of the status of discovery in the Plaintiff Kramer matter

as the matters were only consolidated on February 23, 2024.

However, it should be noted that a new party only recently filed

an answer so it is anticipated that additional discovery is

outstanding in that matter as well.

15. The above discovery is critical and necessary to the

undersigned’s ability to defend this matter.
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16. This outstanding discovery could not have been completed

sooner as the new injury and resumed treatment could not have been

anticipated by the parties or counsel.

17. No party will be prejudiced if the instant application

is granted.

18. All parties will be prejudiced if the above outstanding

discovery is not completed.

19. Defendant requests that the discovery end date be

extended to October 30, 2024 in order to complete the following

discovery:

Discovery To Be Completed By:

20. These matters are not currently the subject of any

arbitration, case management conference, or trial date.

21. The undersigned has received consent from my adversaries

to file the instant application to extend discovery.

22. Should the Court be inclined to deny the instant

application, then it is respectfully requested that these

consolidated matters be scheduled for a case management conference

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so the discovery schedule can be addressed with the Court and all

counsel.

I hereby certify that the foregoing statements made by me are

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

willfully false, I am subject to punishment.

Jenna K. Clemente

DATED: March 6, 2024

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PROOF OF SERVICE

The undersigned hereby certifies that:

1. On March 6, 2024, I caused to be delivered to the

addressees listed below, by E-filing, a copy of the within Notice

of Motion.

Anneris V. Hernandez, Esq.
FREDSON STATMORE BITTERMAN, LLC
200 Broadacres Drive, Suite 180
Bloomfield, New Jersey 07003
Attorney for Plaintiff, Diane Kramer

Sander Budanitsk, Esq.
SANDER BUDANITSKY LLC
520 W 1st Ave
Roselle, New Jersey 07203
Attorney for Plaintiff, Rosario Salas

David Cramer, Esq.
WALSH PIZZI O'REILLY FALANGA LLP
15th Floor, Three Gateway Center
100 Mulberry St, Newark, NJ 07102
Attorney For Defendants, World Subaru, LLC and
688 Shrewsbury, LLC

Erica Tiffany Parkes, Esq.
LAW OFFICE OF LESLIE A. DETORRES
300 Executive Drive Suite 230
West Orange, New Jersey 07052
Attorney for Defendant, Rosario Salas

The foregoing statement made by me is true. I am aware that

if the statement is willfully false, I am subject to punishment.

Jenna K. Clemente

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Exhibit
A
ESX-L-000458-23
ESX-L-001615-24 10/06/2023
03/06/202412:22:38
11:36:17PM
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of12 Trans
TransID:
ID:LCV20233065114
LCV2024590259

200 Broadacres Drive, Suite 180, Bloomfield, New Jersey 07003-3156

973-777-8600 973-777-8645
www.fredsonstatmore.com
BARRY FREDSON (Retired) ✽ ☐ ○ ✽ CERTIFIED BY THE SUPREME COURT
ANDREW L. STATMORE ☐ ○ ♢ ☆ OF NJ AS A CIVIL TRIAL ATTORNEY
LANCE J. BITTERMAN ☐ ☐ MEMBER NEW JERSEY BAR
NICHOLAS J. WALTMAN ☐ ○ ○ MEMBER NEW YORK BAR
MICHAEL A. GALLARDO☐ ○ ♢ MEMBER FLORIDA BAR
RONALD W. SOLARES ☐ ○
☆ MEMBER D.C. BAR
ARJUN A. SHARMA ☐ ○

ALEXANDRA LOPRETE ☐ ○

ANNERIS V. HERNANDEZ ☐ ○

ALPHONSE PETRACCO☐

October 2, 2023
Via E-filing
Superior Court of New Jersey
Essex County - Civil Division

Re: Kramer, Diane v. World Subaru, LLC, et als.
Docket No.: ESX-L-458-23
Our File No.: 27421

Dear Sir/Madam:

Please be advised that we represent the Plaintiff in the above matter. In that regard, and
in order to facilitate litigation in this matter, I respectfully request, pursuant New Jersey Civil
Rule 4:24-1(c), that discovery be extended for a period of sixty (60) days, from December 19,
2023 to February 17, 2024. We are making this request with the consent of my adversaries.

Thank you for your kind consideration in this matter. Please contact me immediately
should you require additional information in this matter.
Respectfully submitted,
FREDSON STATMORE BITTERMAN, LLC

/s/ Anneris V. Hernandez
ANNERIS V. HERNANDEZ, ESQ.
AVH/ kl

CC: David D. Cramer, Esq. and Michele Benenato, Esq. via e-filing.
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Exhibit
B
ESX-L-001615-24
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Jenna K. Clemente, Esq.
NJ Attorney ID 275792018
Mark S. Kundla, Esq.
NJ Attorney ID 027361981
HARDIN, KUNDLA, MCKEON & POLETTO
COUNSELLORS AT LAW
A PROFESSIONAL CORPORATION
Granted.
673 MORRIS AVENUE

SPRINGFIELD, NEW JERSEY 07081
(973) 912-5222

Attorneys for Defendant, Diane C. Barr-Kramer

DIANE KRAMER, :
SUPERIOR COURT OF NEW JERSEY
Plaintiff, : LAW DIVISION: ESSEX COUNTY
Docket No. ESX-L-458-23
vs. :
Civil Action
WORLD SUBARU, LLC, 688 :
SHREWSBURY, LLC, CORPORATION
SERVICE COMPANY, ROSARIO SALAS, : ORDER
ALLSTATE NEW JERSEY PROPERTY
AND CASUALTY INSURNACE COMPANY, :

Defendants. :
ROSARIO SALAS, :
SUPERIOR COURT OF NEW JERSEY
Plaintiff, : LAW DIVISION: UNION COUNTY
vs. Docket No. UNN-L-3340-23
:
DIANE C. BARR-KRAMER, Civil Action
:
Defendants.
: ORDER
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This matter having been opened to the Court upon the

application of Hardin, Kundla, McKeon & Poletto, P.A., attorneys

for defendant, Diane C. Barr-Kramer, for an Order consolidating

the case of Kramer v. World Subaru, LLC, et al., bearing Docket

No. ESX-L-458-23, with the case of Salas v. Barr-Kramer, et al.,

bearing Docket No. UNN-L-3340-23; and for an Order transferring

the venue of Salas v. Barr-Kramer, et al. (UNN-L-3340-23) from

Union County to Essex County and extending discovery in the Kramer

matter, and the Court having considered the moving papers and for

good cause shown;

IT IS on this 23RD day of February , 2024,

ORDERED that Salas v. Barr-Kramer, et al. (UNN-L-3340-23) is

transferred from Union County to Essex County and is consolidated

with Essex County Docket No.: ESX-L-0458-23; and it is further

ORDERED that the above-entitled actions Kramer v. World

Subaru, LLC, et al. and Salas v. Barr-Kramer, et al. be and are

hereby consolidated for discovery and trial in the Superior Court

of New Jersey, Law Division, Essex County as the cases involve

common questions of law and fact arising out of the same incident;

and it is further
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ORDERED that the discovery end date in the consolidated

matters is October 30, 2024; and it is further

ORDERED that the Motion to Consolidate and Transfer Venue is

GRANTED.

ORDERED that the discovery end date shall be determined by

the trial judge

ORDERED that a copy of this Order shall be served upon all

counsel via E-Courts.

/s/ Sheila Venable____
A.J.S.C.

__X__ Unopposed

____ Opposed
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ESX-L-0458-23
STATEMENT OF REASONING

The matters arose out of the same motor vehicle accident, which occurred on September 29, 2022,
in Chatham, Morris County, New Jersey. See Union Compl.

On January 19, 2023, Diane Kramer (“Essex Plaintiff”), filed a Complaint against World Subaru,
LLC., 688 Shrewsbury, LLC., Corporation Service Company, Rosario Salas, Allstate New Jersey
Property and Casualty Insurance Company, and fictitious defendants in Essex County (‘Essex
Action”). See Essex Compl. Essex Plaintiff resides in Monroe, Middlesex County, New Jersey. Id.
Essex Plaintiff alleges injuries as a result of a January 23, 2022, slip and fall and a September 29,
2022, motor vehicle accident. Id.

On October 11, 2023, Rosario Salas (“Union Plaintiff”), filed a Complaint against Diane C. Barr-
Kramer in Union County (“Union Action”). See Union Compl. Union Plaintiff resides in Union,
Union County, New Jersey. Id. Union Plaintiff alleges personal injuries arising out of the
September 29, 2022, motor vehicle accident involving Defendant, Diane C. Barr-Kramer. Id.

On January 29, 2024, Diane C. Barr-Kramer (“Moving Plaintiff/Defendant”), filed this instant
Motion to Consolidate and Transfer Venue. See Cert. of Jenna K. Clemente. Moving
Plaintiff/Defendant alleges that the above actions, in part, arise out of the same September 29,
2022, motor vehicle accident. Id. ¶ 9. Accordingly, Moving Plaintiff/Defendant argues the above
actions involve common questions and law and fact. Id. ¶ 10. Id. ¶ 17. Moving Plaintiff/Defendant
argues the above actions overlap parties and, for at least a portion of the Essex Plaintiff, arise out
of the same motor vehicle accident on September 29, 2022. Id. ¶ 19. Moving Plaintiff/Defendant
argues that a consolidation of the above actions will facilitate the necessity of duplicate trials upon
identical issues of law and fact and a consolidation of these actions will more efficiently utilize the
time of the court, the parties, and counsel. Id. ¶¶ 21-22. Moving Plaintiff/Defendant also argues
that a consolidation of these actions will prevent the risk of potentially inconsistent verdicts. Id. ¶
23. See also Moraes v. Wesler, 439 N.J. Super. 375 (App. Div. 2015). Moving Plaintiff/Defendant
also explains that while the Essex Action is older than the Union Action, an additional party only
recently filed an answer in the Essex Action on October 27, 2023. Id. ¶ 24. Moving
Plaintiff/Defendant explain the consolidation of the above matters will not significantly delay the
completion of discovery or the state of trial as these cases will need to be tried together. Ibid.
Moving Plaintiff/Defendant request that the new discovery end date for the consolidated actions
be adjusted to October 30, 2024. Id. ¶ 29. Therefore, Moving Plaintiff/Defendant respectfully
request the Court to enter an Order consolidating the above actions and to change venue to Essex
County, pursuant to R. 4:48-1. Id. ¶ 28.

No Opposition filed.

“R. 4:38-1 provides: “When actions involving a common question of law or fact arising out of
the same transaction or series of transactions are pending in the Superior Court, the court on a
party’s or its own motion may order the actions consolidated.” (emphasis added) R. 4:38-1.
Further, “[i]f the actions are not triable in the same county or vicinage, the order shall be made
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by the Assignment Judge of the county in which the venue is laid in the action first instituted….”
Id.

Here, the first action, ESX-L-0458-23, was filed in Essex County. Therefore, the Assignment
Judge of Essex County has jurisdiction of this Motion under R. 4:38-1.

“R. 4:38-1 makes no express provision for a change of venue….” Robert T. Winzinger, Inc. v.
Brennan Bros. Inc., 191 N.J. Super. 114, 119 (Law Div. 1983). Generally, the Assignment Judge
has discretion to consolidate cases, and the decision will be set aside only “if it manifestly
erroneous.” See Pressler & Verniero, Current N.J. Court Rules, cmt. 1 on R. 4:38-1 (2022)
(citing Moraes v. Wesler, 439 N.J. Super. 375, 378-379 (App. Div. 2015). The rule provides: “If
actions pending in different venues are consolidated, the order shall specify the venue in which
the consolidated action shall proceed….” R. 4:38-1(c)(2). “This language invites the discretion
by the Assignment Judge; [s]he may therefore select venue on the basis of fairness after a
consideration of all facts.” Winzinger, 191 N.J. Super. at 119.

Here, the Essex County and Union County actions, in part, arise out of the same motor vehicle
accident. The two actions involve Essex Plaintiff and Union Defendant, Diane C. Barr-Kramer,
and Essex Defendant and Union Plaintiff, Rosario Salas. Essex Plaintiff resides in Middlesex
County and Union Plaintiff resides in Union County. Allstate New Jersey Property and Casualty
Insurance Company conducts business through out the State of New Jersey, including Essex
County. This Court finds that in the interest of avoiding duplicate work, preserving judicial
resources, and preventing contradictory findings of fact and conclusions of law, the pending
actions will be consolidated, and the consolidated actions shall proceed in Essex County.

For the foregoing reasons, Plaintiff/Moving Defendant’s Motion to Consolidate is GRANTED,
and the consolidated actions shall proceed in Essex County under Docket No.: ESX-L-0458-23.
Additionally, the trial judge shall determine the discovery end date.

Case Info

Judge

Richard T Sules Track Judge’s New Case

Case No.

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Document Filed Date

March 06, 2024

Case Filing Date

October 11, 2023

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Motion,Ex Parte: Salas Rosario Vs Barr-Kramer Diane

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