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WILEY LAVENDER P.C.
216 AMBOY AVENUE
P.O. BOX 429
METUCHEN, NEW JERSEY 08840
TEL: (732) 494-6099
JOHN F. WILEY, JR. FAX: (732) 494-3944 Email:
john@wileylavender.com
LARRYA. LAVENDER, JR.
Em
larry@wileylavender.com
JAMES B. DUDLEY
Em
james@wileylavender.com
PANKAJ MAKNOOR
Email:
pankaj@wileylavender.com
September 9, 2020
Via eCourts
Superior Court of New Jersey
Middlesex County Courthouse
Law Division
56 Paterson Street
New Brunswick, NJ 08901
Re: Michele Pickett and Brian Pickett v. Albert D. Kusi-Appouh, A.B.C
Companies and John Does
Docket No:
Dear Clerk
Please be advised that this firm represents plaintiffs, Michele Pickett and Brian Pickett, in
the above captioned matter. The following documents are being filed with the Court through
Ecourts:
{XX} $250.00 (Paid through JACS)
{XX} Complaint
{XX} CIS form (eCourts Generated)
Please process the enclosures and contact my office should the Court have any questions
or concerns. Thank you.
Very truly yours,
y
YlMAKNOOR, ESQ
encl.
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WILEY LAVENDER, P.C.
LARRY A. LAVENDER, JR., ESQ. (005341985)
JAMES B. DUDLEY, ESQ. (005341985)
PANKAJ MAKNOOR, ESQ. (175292016)
216 AMBOY AVENUE
P.O. BOX 429
METUCHEN, NEW JERSEY 08840
(732) 494-6099
Attorney for Plaintiffs, Michele Pickett and Brian Pickett
MICHELE PICKETT and ) SUPERIOR COURT OF NEW JERSEY
BRIAN PICKETT ) MIDDLESEX COUNTY
Plaintiffs ) LAW DIVISION
-Vs-
) CIVIL ACTION
) DOCKET NO:
ALBERT D. KUSI-APPOUH; )
A.B.C. COMPANIES (1-100) )
(fictitious entities); and ) COMPLAINT, JURY DEMAND,
JOHN DOES (1-100) ) DESIGNATION OF TRIAL ATTORNEY,
(fictitious persons) ) DEMAND FOR INSURANCE
Defendants ) INFORMATION, NOTICE TO PRODUCE,
) DEMAND FOR ANSWERS TO UNIFORM C
) AND C(1) INTERROGATORIES AND
) SUPPLEMENTAL INTERROGATORIES
Plaintiffs, MICHELE PICKETT and BRIAN PICKETT (collectively “Plaintiffs”), by
way of complaint against the defendants, ALBERT D. KUSI-APPOUH, A.B.C. COMPANIES
(1-100) and JOHN DOES (1-100) (collectively “Defendants”) allege as follows:
PARTIES
1. At all times relevant hereto, plaintiffs, MICHELE PICKETT, Wife, and BRIAN PICKETT,
her Husband, reside at 57 Cherry Street in the Township of Edison, County of Middlesex and
State of New Jersey.
2. Upon information and belief, defendant, ALBERT D. KUSI-APPOUH resides at 38 Boyden
Pkwy, 2" Floor, in the Township of Maplewood, County of Union and State of New Jersey.
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At all times relevant hereto, defendants, ABC COMPANIES (1-100), and / or JOHN DOES
(1-100), are fictional defendants designated as persons, individuals, corporations,
partnerships, proprietorships, or business entities responsible, individually and/or jointly and
severally, or by their agents, servants, and/or employees for the ownership, control,
management, care, and operation of the aforesaid motor vehicle.
At all times relevant hereto, defendants, as owners and/or operators of the aforesaid motor
vehicle, were responsible, individually, and/or jointly and severally, and /or by their agents,
servants, and/or employees for managing, controlling, supervising and maintaining the motor
vehicle so as to operate the aforesaid motor vehicle in a safe manner and to not permit any
dangerous and / or hazardous operation to arise and occur.
VENUE/JURISDICTION
The cause of action alleged herein arises from an automobile accident that took place in
Middlesex County.
The Plaintiffs in this action reside in Middlesex County.
The relief sought by Plaintiffs is monetary and the amount in controversy exceeds
$15,000.00.
Venue and jurisdiction are proper pursuant to R. 6:1-2(a)(2) and R. 4:3-land R. 4:3-2.
COUNT ONE
On or about January 11, 2019, plaintiff, MICHELE PICKETT, was lawfully operating her
motor vehicle travelling southbound on Ryders’ Lane in the Borough of Milltown, County of
Middlesex, and State of New Jersey.
10 At the time and place aforesaid, the defendant, ALBERT D. KUSI-APPOUH was the driver
and owner of an automobile, which was also travelling southbound on Ryders Lane in the
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Borough of Milltown, County of Middlesex, and State of New Jersey.
ll At the time and place aforesaid, the defendant, ALBERT D. KUSI-APPOUH, was negligent
and careless in operating his vehicle so as to strike and collide with the vehicle being
operated by the plaintiff, MICHELE PICKETT.
12 As a direct proximate result of the negligence of defendant, ALBERT D. KUSI-APPOUH, in
operation, control, maintenance and/or supervision of said motor vehicle, a collision occurred
and the plaintiff, MICHELE PICKETT was caused to sustain severe, serious and permanent
injuries. Plaintiff, MICHELE PICKETT was caused to suffer great pain and anguish and will
in the future be caused to suffer great pain and anguish; she was caused to lose time from her
employment and will, in the future, be caused to lose time from her employment; she was
caused to incur medical expenses and will, in the future be caused to incur medical expenses;
and she has been and will be in the future be disability and prevented from attending to her
necessary affairs and business.
13 As a result of aforesaid negligent acts of the Defendant, ALBERT D. KUSI-APPOUH, the
personal property of plaintiff MICHELE PICKETT, was also damaged and/or destroyed
thereby depriving her of the use and enjoyment of said personal property.
WHEREFORE, plaintiff, MICHELE PICKETT demands judgment against the
defendant, ALBERT D. KUSI-APPOUH for compensatory damages, interest, costs and such
other relief as this court deems equitable and just under the circumstances.
SECOND COUNT
14. Plaintiff, MICHELE PICKETT repeats and reasserts the allegations contained in the First
Count of this Complaint as if more fully set forth at length herein.
15. At the time and place aforesaid, JOHN DOES 1-100 and ABC CORPORATIONS 1-100,
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negligently and/or carelessly operated, owned, maintained, controlled and/or supervised said
motor vehicle and as a direct result of said negligence, caused the collision at issue herein.
16 As a direct proximate result of the negligence of defendants, JOHN DOES 1-100 and ABC
CORPORATIONS 1-100, plaintiff, MICHELE PICKETT was caused to sustain severe,
serious and permanent injuries. Plaintiff, MICHELE PICKETT was caused to suffer great
pain and anguish and will in the future be caused to suffer great pain and anguish; she was
caused to lose time from her employment and will, in the future, be caused to lose time from
her employment; she was caused to incur medical expenses and will, in the future be caused
to incur medical expenses; and she has been and will be in the future be disability and
prevented from attending to her necessary affairs and business.
WHEREFORE, plaintiff, MICHELE PICKETT demands judgment against the
defendants, JOHN DOES 1-100 and ABC CORPORATIONS 1-100, jointly, severally, or in the
alternative for compensatory damages, interest, costs and such other relief as this court deems
equitable and just under the circumstances.
COUNT THREE
17. Plaintiff, MICHELE PICKETT repeats and reasserts the allegations contained in the First
and Second Counts of this Complaint as if more fully set forth at length herein.
18. The Plaintiffs herein allege that there was a breach of N.J.S.A. 39:4-1, et seg. and other
regulations and that constitutes a statutory tort.
WHEREFORE, plaintiff, MICHELE PICKETT demands judgment against the
defendants, ALBERT D. KUSI-APPOUH, JOHN DOES 1-100 and ABC CORPORATIONS 1-
100, jointly, severally, or in the alternative for compensatory damages, interest, costs and such
other relief as this court deems equitable and just under the circumstances.
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COUNT FOUR
19. Plaintiff, BRIAN PICKETT repeats and reasserts the allegations contained in the First,
Second and Third Counts of this Complaint as if more fully set forth at length herein.
20. Plaintiff, BRIAN PICKETT, is the husband of the plaintiff, MICHELE PICKETT.
21. As a result of the injuries sustained by the plaintiff, MICHELE PICKETT, plaintiff, BRIAN
PICKETT, has, and in the future will be caused to, expend monies for medical treatment of
plaintiff, has and in the future will suffer the loss of services and society of the plaintiff,
MICHELE PICKETT.
WHEREFORE, plaintiffs, MICHELE PICKETT and BRIAN PICKETT, demands
judgment against the defendants, ALBERT D. KUSI-APPOUH, JOHN DOES 1-100 and ABC
CORPORATIONS 1-100, jointly, severally, or in the alternative for compensatory damages,
interest, costs and such other relief as this court deems equitable and just under the
circumstances.
WILEY LAVENDER, P.C.
Attorneys for Plaintiffs
Dated: September 9, 2020 By:
PANKASMAKNOOR, ESQ
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JURY DEMAND
Plaintiffs put all parties on notice of a demand for trial by jury as to all issues.
DESIGNATION OF TRIAL COUNSEL
Plaintiffs hereby designate, James B. Dudley, Esq. and Pankaj Maknoor, Esq. of Wiley
Lavender, P.C. as the trial counsel in the above captioned litigation pursuant to Rule 4:25-4.
CERTIFICATION OF NO OTHER ACTIONS
To the best of our knowledge or belief, the matter in controversy is not the subject of any
other action pending in any other Court or pending arbitration proceedings We recognize the
continuing obligation of each party to file and serve on all parties and the Court an amended
certification if there is a change in the facts stated in this original certification.
DEMAND FOR DISCOVERY OF INSURANCE COVERAGE
Pursuant to Rule 4:10-2(b), demand is hereby made that defendants disclose to plaintiffs’
attorney whether there are any insurance agreements or policies under which any person or firm
carrying on an insurance business may be liable to satisfy part of all of the a judgment and
provide plaintiffs’ attorney with true copies of such insurance agreement or policies including,
but not limited to, any and all declaration sheets. This demand shall be deemed to include and
cover not only primary coverage but also any and all excess catastrophe and umbrella policies.
NOTICE TO PRODUCE
Pursuant to Rule 3:18-1, the plaintiffs hereby demand that the defendants produce the
following documentation within thirty (30) days as prescribed by the Rules of the Court.
Additionally, please be advised that the following requests are ongoing and continuing in nature
and the defendants are therefore required to continuously update its response thereto as new
information or documentation comes into existence.
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The amounts of any and all insurance coverage covering the defendant, including but not
limited to, primary insurance policies, secondary insurance policies, and/or umbrella
insurance policies. For each such policy of insurance, supply a copy of the declaration page
there from.
Copies of any and all documentation or reports, including but not limited to, police reports,
accident reports, and/or incident reports concerning the happening of the incident in
questions or any subsequent investigation of same.
Copies or duplicates of any and all photographs, motion pictures, videotapes, films,
drawings, diagrams, sketches of other reproductions, descriptions or account concerning the
individuals involved in the incident in question, the property damages sustained, the accident
scene, or anything else relevant to the incident in question.
Copies of any and all signed or unsigned statements, documents, communications, and/or
transmissions, whether in writing, made orally or otherwise recorded by any mechanical or
electronic means, made by any party to this action, any witness, or any other individual,
businesses, corporation, investigative authority or other entity concerning anything relevant
to the incident in question.
Copies of any and all documentation, including but not limited to, any contracts between the
owner of the property, motor vehicle, or product involved in the incident in question and all
of the parties involved in this matter.
Copies of any and all documentation, including but not limited to safety manuals, statutes,
rules, regulations, books, and/or industry standards which refer to, reflect or otherwise relate
to the incident in question or any potential defense to the action in question.
Copies of any and all discovery received from any other parties to the action in question.
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8. Copies of any and all reports on the plaintiffs received by the defendants or any other party
this suit, from either the Central Index Bureau (C.LB.) of from any other source.
9. Copies of any and all medical information and/or documentation concerning the plaintiffs in
this matter whether it concerns any medical condition of the plaintiffs in this matter; whether
it concerns any medical condition or treatment which took place before, during or after the
time of the incident in question.
10. Copies of any and all records of any type subpoenaed by the defendant or received from any
other source concerning the plaintiffs of the incident in question.
DEMAND FOR ANSWERS TO INTERROGATORIES
Demand is hereby made on the defendants to answer fully and responsively Form C and
Form C(1) Uniform Interrogatories, found in Appendix II as provided by Rule 4:17-1(b)(ii) and
other applicable Rules of Court. Demand is hereby made that Defendants answer the attached
Supplemental Interrogatories as prescribed by the Rules of Court.
1 At the moment of impact, set for the speed of all vehicles involved in the accident.
2. Provide your cell phone number for the time of the accident and the carrier associated with
that cell phone.
State why you were unable to avoid the collision.
List all inaccuracies contained in the police report.
List of all steps you took to avoid the collision.
State how long before the collision you observed the vehicle that you first impacted.
List all injuries you sustained in this accident.
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Please is entitled to up to ten (10) supplemental interrogatories per defendant pursuant to
Rule 4:17-1(b)(1). Plaintiffs explicitly reserve their right to ask any additional supplemental
interrogatory questions after service of defendant’s answer, pursuant to Rule 4:17-2.
NOTICE REGARDING DEFENSE MEDICAL EXAMINATIONS
Please be advised that the plaintiff hereby objects to the taking of any photographs, x-
rays or other reproductions concerning the plaintiff of the plaintiff's injuries at the time of the
defense examination. The plaintiff is not obligated under any Court Rule to bring any records,
diagnostic films or other items to defense medical examination. Therefore, any such request will
be ignored.
Defendants are specifically put on notice that if any defense medical examiner required
such information, it should be provided to the doctor by defense counsel and not by the plaintiff.
Additionally, the plaintiff will not be providing the defense medical examiner with any
information other than to provide valid photo identification for the purpose of verifying his/her
identify. The plaintiff will not be filing out any paperwork at the time of the examination. Any
paperwork required by the examiner should be completed by the defense counselor requesting
the defense medical examination prior to the happening of the examination. If the defense
counsel requires information that is not in their possession to complete said paperwork, the
proper discovery requests should be made to plaintiff through their counsel.
WILEY LAVENDER, P.C.
Attorneys for Plaintiffs
Dated: September 9, 2020 By:
ff]
/
PANKAI MAKNOOR, ESQ.
v
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Civil Case Information Statement
Case Details: MIDDLESEX | Civil Part Docket# L-006462-20
Case Caption: PICKETT MICHELE VS KUSI-APPOUH Case Type: AUTO NEGLIGENCE-PERSONAL INJURY (VERBAL
ALBERT THRESHOLD)
Case Initiation Date: 09/09/2020 Document Type: Complaint with Jury Demand
Attorney Name: PANKAJ MAKNOOR, Jury Demand: YES - 6 JURORS
Firm Name: WILEY LAVENDER PC Is this a professional malpractice case? NO
Address: 216 AMBOY AVE Related cases pending: NO
METUCHEN NJ 08840 If yes, list docket numbers:
Phone: 7324946099 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Pickett, Michele transaction or occurrence)? NO
Name of Defendant's Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Michele Pickett? NO
Are sexual abuse claims alleged by: Brian Pickett? 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)
09/09/2020 /sneed/ PANKAJ MAKNOOR
Dated Signed
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