HomeMy WebLinkAbout07-6236~~ ..~
Hubert X. Gilroy, Esquire
Attorney I.D. No. 29943
Katie J. Maxwell, Esquire
Attorney I..D. No. 206018
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
KATHLEEN MOAT, et als, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 07 - G~ 3 4 CIVIL TERM
BERGEN REALTY PROPERTIES, LLC.,
et als.,
Defendants
BERGEN REALTY PROPERTIES, LLC CIVIL ACTION -LAW
JP MANAGEMENT COMPANY,
Defendant/Third Party
Plaintiffs :
vs.
THE BOROUGH OF BERGENFIELD and
THE BOROUGH OF BEGENFIELD FIRE
DEPARTMENT,
Third Party Defendant
PETITION TO OPEN A DOCKET
FOR ISSUANCE OF A SUBPOENA
AND NOW, comes MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER,
and hereby moves the Court as follows:
1. The above-referenced case is pending in the Superior Court of New Jersey, Law
Division, Bergen County, docketed at No. BER-L-8740-05.
2. The Superior Court in New Jersey has issued a Commission to take the out-of--state
deposition of a witness located in Pennsylvania.
3. The witness is Central Locating Services, Ltd., an entity previously located at 4000
Bordentown Road, Suite 24, Sayreville, New Jersey, but currently conducts business at 401 East
Lowther Street, Suite 302, Carlisle, Cumberland Coup
4• The Order issued by the Honorable Es ~' Pe~sYlvania.
appropriate Courtin Pennsylvania open a docket so tela M. De La Cruz, J.C.S., requested that the
that a Pennsylvania subpoena can be issued for
Central Locating Services, Ltd.
5• The original Order/Commission signed b the
J.C.S., acid containing the official seal of the Clerk of they Honorable Estela M. De La Cruz,
County, Mary E. Demmer, is hereby attached as Exh' Superior Court of New Jersey for Bergen
WHEREFO~~ this Petition is filed re ibit "A".
issuance of a subpoena in the above-referenced ma sting the Court open a docket number for the
tter.
MARTSON LAW OFFICES
By ~ ~
Hubert X. Gilroy, Esquire
I.D. No. 29943
Katie J. Maxwell, Esquire
L.D. No. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys as Local Counsel for
Supreme Tank Company, Inc., d/b/a
American Tank Services and
Mitchell Supreme Fuel Company, Inc.
Date: /G~~ 3/~
~ ~
RIKER DANZIG SCHERER HYLAND & PERRETTI LLP
Headquarters Plaza, One Speedwell Avenue
Morristown, NJ 07962-1981
(973) 538-0800
Attorneys for Defendants,
Supreme Tank Company, Inc., d/b/a American Tank Services; and
Mitchell Supreme Fuel Company, Inc.
KATHLEEN MOAT, et als
Plaintiffs,
vs.
BERGEN REALTY PROPERTIES, LLC., et als.
Defendants.
BERGEN REALTY PROPERIES, LLC and
JP MANAGEMENT COMPANY,
Defendant/Third
Party Plaintiffs,
vs.
THE BOROUGH OF BERGENFIELD and
THE BOROUGH OF BERGENFIELD FIRE
DEPARTMENT,
Third Party Defendant.
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION, BERGEN COUNTY
DOCKET NO. BER-L-8740-OS
CIVIL ACTION
COMMISSION TO TAKE
OUT OF STATE DEPOSITION
(Central Locating Services, Ltd.)
consolidated captions omitted
TO: The Judges of the State of Pennsylvania:
WHEREAS, it appears to the Superior Court of New Jersey, Law Division,
Bergen County, that Central Locating Services, Ltd., an entity .previously located at 4000
Bordentown Road, Suite 24, Sayreville, New Jersey, and that currently conducts business at
401 East Louther Street, Suite 302, Carlisle, Pennsylvania, is a material witness in the
above-captioned action, we request that you issue a subpoena duces tecum to a
representative of Central Locating Services, Ltd. compelling said representative to submit to
a deposition and give testimony and produce documents related to the claims and defenses
of the parties in this matter.
Dated: this _~~ ~-~day of 2007
O icial e 1, Clerk
Superior Court of New Jersey
Mary E. Demmer
Special Deputy Clerk of
The Superior Court,
Bergen County
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KA"THLEEN MOAT, et als,
Plaintiff
vs.
BERGEN REALTY PROPERTIES, LLC.,
et als.,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07 - (a a3~o CIVIL TERM
BERGEN REALTY PROPERTIES, LLC CIVIL ACTION -LAW
JP MANAGEMENT COMPANY,
Defendant/Third Party
Plaintiffs
vs.
THE BOROUGH OF BERGENFIELD and
THE BOROUGH OF BEGENFIELD FIRE
DEPARMENT,
Third Party Defendant
ORDER OF COURT
AND NOW, this ?o' day of October, 2007, the attached Motion for Commission to
Take Out of State Deposition is GRANTED.
By the Court,
~S ~fi Q~ 1~0 tODZ
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