TESTA, HECK, TESTA WHITE, P.A. Counselors at Law 424 LANDIS AVENUE VINELAND, NEW JERSEY 03 860-8198 A Professional Corporation CUM-L-000486-18 07/12/2018 10:04:39 AM Pg 1 of 4 Trans ID: LCV20181209112 TESTA HECK SCROCCA TESTA A Professional Corporation Justin R. White (Attorney ID 041792005) 424 Landis Avenue Vineland, New Jersey 08360 856?691-2300 Attorney for Plaintiff SUPERIOR COURT OF NEW JERSEY MARY FRANSKO, LAW DIVISION CUMBERLAND COUNTY Plaintiff DOCKET NO: CUM-L- NELSON T. ALBANO, JOHN 1-5, and CORPORATIONS CIVIL ACTION 1-5, j/s/a, COMPLAINT, JURY DEMAND AND DESIGNATION OF De?ndam TRIAL COUNSEL The plaintiff, Mary Fransko, residing at 545 Alps Place, in the City Of Vineland, County Of Cumberland, and State Of New Jersey, by way of Complaint against the defendants, says: FIRST COUNT 1. On or about August 15, 2016, Plaintiff Mary Fransko was a rear seated passenger Of a being Operated by defendant, Nelson T. Albano (?Albano?), traveling northbound at a high rate of speed, on the Garden State Parkway at or near mile post 9.30 in Middle Township, Cape May County, New Jersey. Traf?c ahead Of them had stopped. Defendant, Albano failed to Observe the stopped vehicles ahead of him and as a result, lost control Of the Defendant, Albano attempted to lay the bike down. Due to the high rate of speed, plaintiff fell Off the and slid across the pavement resulting in serious personal injuries. TESTA, HECK, TESTA WHITE, P.A. A Professzonal Corporation CUM-L-000486-18 07/12/2018 10:04:39 AM Pg 2 of 4 Trans ID: LCV20181209112 Counselors at Law 424 LANDIS AVENUE VINELAND, NEW JERSEY 03860?8198 2. Said collision was a proximate result of the negligence of Defendant Nelson T. Albano. Defendant Nelson T. Albano, was negligent in that he carelessly and recklessly without notice, signal or warning of any kind lost control of the which Plaintiff was a rear-passenger, and causing it to land sideways on the pavement, causing plaintiff to slide across the roadway. Defendant Nelson T. Albano was further careless and negligent in that he: a) failed to maintain a proper lookout at all times; b) failed to keep said vehicle under safe and proper control at all times; c) failed to give proper and adequate warning of intentions; d) failed to apply his brakes at a proper time; e) failed to avoid an accident; t) disregarded the rights of others; g) was otherwise careless and negligent. 4. Plaintiff alleges that an insufficient amount of time has elapsed within which to determine the identity or identities of any other individual(s) or corporation(s) who may be responsible in whole or in part for the accident herein described. For the purpose of the within Complaint said individual(s) and corporation(s) have been designated as John Doe(s) I- and Corporations, as the owners, operators, lessors, lessees, managers of defendants and those responsible for the maintenance and repair of the vehicle in question and any establishment or individuals licensed to serve alcoholic beverages. When the proper name of any other proper party becomes known, the Complaint will be amended accordingly and the proper name of the person inserted therein. TESTA, HECK, TESTA WHITE, PA. A Professzonal Corporation Counselors at Law 424 LANDIS AVENUE VINELAND, NEW JERSEY 03860-8198 CUM-L-000486-18 07/12/2018 10:04:39 AM Pg 3 of 4 Trans ID: LCV20181209112 5. As a direct and proximate result of Defendants? negligence as aforesaid, Plaintiff Mary Fransko sustained temporary and permanent injuries, has been disabled and will be disabled, has been required and will be required to seek medical help in an effort to cure herself of her injuries, has incurred medical expenses in an effort to cure herself of her injuries, has endured and will endure pain and suffering, has been hospitalized and may in the future be hospitalized in an effort to cure herself of her injuries, may in the future undergo surgery in an effort to cure herself of her injuries, has been permanently scarred, has sustained a loss of earnings, has sustained a loss of earning capacity, has sustained and will sustain emotional and mental distress concerning her injuries, and has been and will be otherwise damaged. 6. Plaintiff Mary Fransko has sustained a permanent injury to a body part, which meets the criteria of the New Jersey Automobile Reparations Reform Act as amended effective January 1, 1989 and as amended in 1998, N.J.S.A. WHEREFORE, Plaintiff Mary Fransko demands judgment against Defendants Nelson T. Albano, John Doe(s) 1-5 and Corporation(s) 1-5 for damages, interest, and costs of suit. DEMAND FOR JURY TRIAL Plaintiff herewith demands a trial by jury in accordance with the Rules of Civil Practice. DESIGNATION OF TRIAL COUNSEL Pursuant to Justin R. White, Esquire, is hereby designated as trial counsel in the above-captioned litigation on behalf of Plaintiff Mary ransko. TESTA, HECK, TESTA WHITE, P.A. A Professmnal Corporation Counselors at Law 424 LANDIS AVENUE VINELAND, NEW JERSEY 03 860-8198 CUM-L-000486-18 07/12/2018 10:04:39 AM Pg 4 of 4 Trans ID: LCV20181209112 TESTA HECK TESTA WHITE, PA A Profits}! of Corporation DATED: July 10, 2018 . R. WHITE, ESQUIRE DEMAND FOR ANSWERS TO UNIFORM INTERROGATORIES Plaintiff hereby demands answers to Uniform and interrogatories pursuant to CERTIFICATION PURSUANT TO 4:5-1 1, Justin R. White, Esquire, an attorney at law of the State of New Jersey and a member of the law ?rm of TESTA HECK TESTA WHITE, PA, certify as follows: 1. I am not aware of any other action pending in any Court or of a pending or contemplated arbitration proceeding regarding the matters in controversy in this civil action. 2. I am not aware of the names of any other person or prospective parties who should be joined in this action. 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. TESTA HECK TESTA WHITE, PA A Professional Corporation .1 DATED: July 9, 2018