Preview
ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 1 of 12 Trans ID: LCV20241559314
MEYNER AND LANDIS LLP
David B. Grantz, Esq.
Filing Attorney No.: 042981996
One Gateway Center, Suite 2500
Newark, New Jersey 07102
973-602-3466 * Fax 973-624-0356
dgrantz@meyner.com
Attorneys for Plaintiff
Andrew Schumacher
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
DOCKET NO.:
ANDREW SCHUMACHER,
Plaintiff, Civil Action
v.
COMPLAINT
JUDSON B. SCHUMACHER and NANCY
B. SCHUMACHER
Defendants.
Plaintiff, Andrew Schumacher, by his attorneys Meyner and Landis, LLP, files the
following Complaint against Defendants Judson B. Schumacher and Nancy B. Schumacher as
follows:
PARTIES
1. At times relevant hereto, Plaintiff, Andrew Schumacher (“Plaintiff”), is an
individual residing at 736 N. Western Avenue, #395 Lake Forest, IL 60045.
2. Upon information and belief, Defendant, Judson B. Schumacher (“J.
Schumacher”) is an individual residing at 57 White Oak Ridge, Short Hills, New Jersey 07078.
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3. Upon information and belief, Defendant, Nancy B. Schumacher (“N.
Schumacher”) is an individual residing at 57 White Oak Ridge, Short Hills, New Jersey 07078.
(J. Schumacher and N. Schumacher are sometimes hereinafter referred to as “Defendants”).
JURISDICTION AND VENUE
5. Venue is appropriate in this Court because Plaintiffs’ claims arise from
transactions and occurrences in Essex County, New Jersey and Defendants reside in Essex
County, New Jersey.
FACTUAL BACKGROUND
I. The First Loan
6. On December 9, 2014, Plaintiff agreed to lend Defendants $150,000 and extended
a personal loan to Defendants on that date (the “First Loan”).
7. The First Loan was evidenced by a certain Promissory Note dated December 9,
2014 (the “First Promissory Note”).
8. Pursuant to the First Promissory Note, Plaintiff advanced $75,000 to Defendants
on December 10, 2014, and then another $75,000 to Defendants on December 11, 2014.
9. Interest accrues on the outstanding indebtedness due on the First Promissory Note
at a fixed interest rate of three percent (3%) per annum.
10. As set forth in the First Promissory Note, Defendants agreed to pay Plaintiff all
principal and accrued interest due and payable three (3) years from the date of the First
Promissory Note, or December 10, 2017.
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11. Defendants did not pay Plaintiff the outstanding indebtedness under the First
Promissory Note as agreed.
II. The Second Loan
12. On August 18, 2015, Plaintiff agreed to lend Defendants another $150,000 and
extended a second personal loan to Defendants on that date (the “Second Loan”).
13. The Second Loan was evidenced by a certain Promissory Note dated August 18,
2015 (the “Second Promissory Note”).
14. Pursuant to the Second Promissory Note, Plaintiff advanced $75,000 to
Defendants on August 19, 2015, and then another $75,000 to Defendants on August 20, 2015.
15. Interest accrues on the outstanding indebtedness due on the Second Promissory
Note at a fixed interest rate of three percent (3%) per annum.
16. As set forth in the Second Promissory Note, Defendants agreed to pay Plaintiff all
principal and accrued interest due and payable two (2) years from the date of the Second
Promissory Note, or August 18, 2017.
17. Defendants did not pay Plaintiff the outstanding indebtedness under the Second
Promissory Note as agreed.
III. The Third Loan
18. On or about June 1, 2016, Plaintiff agreed to lend Defendants another $30,000
and extended a third personal loan to Defendants on that date (the “Third Loan”).
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19. The Third Loan was evidenced by a certain Promissory Note dated June 1, 2016
(the “Third Promissory Note”).
20. Pursuant to the Third Promissory Note, Plaintiff advanced $30,000 to Defendants
on June 2, 2016.
21. Interest accrues on the outstanding indebtedness due on the Third Promissory
Note at a fixed interest rate of three percent (3%) per annum.
22. As set forth in the Third Promissory Note, Defendants agreed to pay Plaintiff all
principal and accrued interest due and payable on or before August 31, 2016.
23. Defendants did not pay Plaintiff the outstanding indebtedness under the Third
Promissory Note as agreed.
IV. Defendants’ Defaults and Amounts Due
24. An event of default occurred under the First Promissory Note due to Defendants’
failure to make the required payment of principal and interest due on the December 10, 2017,
Maturity Date (the “First Loan Maturity Default”).
25. An event of default occurred under the Second Promissory Note due to
Defendants’ failure to make the required payment of principal and interest due on the August 18,
2017 Maturity Date (the “Second Loan Maturity Default”).
26. An event of default occurred under the Third Promissory Note due to Defendants’
failure to make the required payment of principal and interest due on the August 31, 2016,
Maturity Date (the “Third Maturity Default”).
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27. The First Maturity Default, Second Maturity Default, and Third Maturity Default
are collectively referred to as the “Stated Defaults”.
28. In March 2018, via email, Defendants acknowledged the amounts were still
outstanding, but failed to make payments on the outstanding indebtedness.
29. On February 17, 2022, Plaintiff wrote to Defendants demanding that Defendants
respond if they disputed the amounts, requesting a full accounting of the amounts due on each
loan, and when Defendants would pay the outstanding amounts due.
30. On February 18, 2022, Defendants confirmed receipt of the February 17, 2022
letter/email and that they were in agreement with the dates, the amounts due and the interest
charges.
31. On March 12, 2022, Defendants offered to repay the outstanding indebtedness
due on the loans in $25,000 quarterly payments and if the $25,000 quarterly payments could not
be maintained, then they would liquidate housing assets as their plan to repay the funds that they
acknowledged owing to Plaintiff.
32. On March 17, 2022, Defendant began to repay the outstanding indebtedness with
an initial $25,000 payment as they offered to do.
33. Payments continued to be made in $25,000 increments on June 6, 2022, August
15, 2022, November 15, 2022, and on February 17, 2023.
34. On May 15, 2023, Defendants made a $15,000 payment, rather than a $25,000
payment as offered.
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35. On August 15, 2023, Defendants made a $10,000 payment rather than a $25,000
payment as offered.
36. On November 30, 2023, Defendants made a $15,000 payment rather than a
$25,000 payment as offered.
37. On February 15, 2024, Defendants made a $10,000 payment rather than a $25,000
payment as offered.
38. By correspondence dated April 12, 2024, Plaintiff, through counsel, declared the
Loans to be in default for failure to repay the amounts due and demanded full payment of the
then outstanding balance due of Two Hundred Forty Thousand Two Hundred Fifty-Six and
94/100 ($240,256.04) Dollars.
39. On May 15, 2024, Defendants made a $25,000 payment and Plaintiff sent a
reservation of rights letter on May 16, 2024 acknowledging receipt of the $25,000 payment and
reserving all rights and remedies.
40. As of May 15, 2024, the outstanding principal balance due on the Loans was
$216,121.64 with per diem interest accruing daily in the amount of $17.76 for May 15, 2024 and
each day thereafter.
FIRST COUNT
(Breach of Contract – First Loan)
41. Plaintiff incorporates and re-alleges the facts and allegations set forth above as if
fully set forth herein at length.
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42. Plaintiff agreed to and did lend $150,000 to Defendants as evidenced by the First
Promissory Note.
43. Pursuant to the First Promissory Note, Defendants agreed to repay Plaintiff
$150,000 by December 10, 2017.
44. Plaintiff agreed to and did lend $150,000 to Defendants as evidenced by the
Second Promissory Note.
45. Pursuant to the Second Promissory Note, Defendants agreed to repay Plaintiff
$150,000 by August 18, 2017.
46. Plaintiff agreed to and did lend $30,000 to Defendants as evidenced by the Third
Promissory Note.
47. Pursuant to the Third Promissory Note, Defendants agreed to repay Plaintiff
$30,000 by August 31, 2016.
48. Defendants failed to repay the outstanding indebtedness due on (a) the First
Promissory Note on or before December 10, 2017, (b) the Second Promissory Note on or before
August 18, 2017, and (c) the Third Promissory Note on or before August 31, 2016.
49. In March 2018, Defendants acknowledged the indebtedness due under the First
Promissory Note, the Second Promissory Note and the Third Promissory Note (collectively the
“Notes’) and assured Plaintiff that the indebtedness would be paid in full.
50. In February 2022 and March 2022, Plaintiff further acknowledged the outstanding
indebtedness due under the Notes, assured Plaintiff the outstanding indebtedness would be paid
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and began to repay the outstanding indebtedness in sporadic incremental payments of $25,000,
$15,000 and $10,000 quarterly from 2022 to 2024.
51. In April 2024, Plaintiff declared Defendants to be in default of the loans and
demanded immediate payment of the outstanding balance due and owing, but Defendants failed
to pay the outstanding balance.
52. As a direct and proximate result of Defendants’ failure to pay the Notes as agreed,
Plaintiff is entitled to damages for breach of contract in the amount of the outstanding
indebtedness due on the First Loan, the Second Loan and the Third Loan (collectively the
“Loans”), plus interest accruing thereon.
WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson
B. Schumacher and Nancy B. Schumacher, jointly and severally, for:
A. The outstanding principal sum of $216,121.64, together with accrued
interest, and other allowed charges;
B. Costs of suit and attorneys’ fees as allowed by law; and
C. For such other relief as the Court deems appropriate.
SECOND COUNT
(Unjust Enrichment- First Loan)
53. Plaintiff incorporates and re-alleges the facts and all allegations set forth
above as if fully set forth herein at length.
54. Defendants received and accepted the Loans from Plaintiff.
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55. Defendants knew or had reason to know that Plaintiff expected to be
repaid the money he lent them with interest.
56. Defendants acknowledged the indebtedness due in 2018 and 2022 and
repeatedly ratified and reaffirmed their obligations to repay the indebtedness due under the
Loans.
57. Plaintiff demanded repayment of the Loans, but despite Plaintiff’s
demands, Defendants failed to pay the amounts owed within a reasonable time after such demand
for payment.
58. Defendants are now indebted to Plaintiff in the total amount, as of May
15, 2024, of $216,121.64, plus interest and other allowed charges.
WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson
B. Schumacher and Nancy B. Schumacher, jointly and severally, for:
A. The outstanding principal sum of $216,121.64, together with accrued
interest, and other allowed charges;
B. Costs of suit and attorneys’ fees as allowed by law; and
C. For such other relief as the Court deems appropriate.
THIRD COUNT
(Collection on Account Stated)
59. Plaintiff incorporates and re-alleges the facts and all allegations set forth above as
if fully set forth herein at length.
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60. Plaintiff repeatedly notified Defendants of the balance due on the Loans.
61. Defendants did not and have not objected or disputed the amount due and owing
to Plaintiff.
WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson
B. Schumacher and Nancy B. Schumacher, jointly and severally, for:
A. The outstanding principal sum of $216,121.64, together with accrued
interest, and other allowed charges on the Account Stated;
B. Costs of suit and attorneys’ fees as allowed by law; and
C. For such other relief as the Court deems appropriate.
MEYNER AND LANDIS, LLP
Attorneys for Plaintiff
Andrew Schumacher
By: /s/ David B. Grantz ________
David B. Grantz, Esq.
One Gateway Center Suite 2500
Newark, New Jersey 07102
Email: dgrantz@meyner.com
Direct: (973) 602-3466
DATED: June 20, 2024
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CERTIFICATION
The undersigned, attorneys for Plaintiff, Andrew Schumacher, hereby certifies in
accordance with Rule 4:5-1 that the within action is not the subject of any other action or pending
arbitration proceeding, nor is any other action or arbitration proceeding contemplated, the
undersigned further certifies that there are no other parties which should be joined in this action.
MEYNER AND LANDIS, LLP
Attorneys for Plaintiff
Andrew Schumacher
By: /s/ David B. Grantz ________
David B. Grantz, Esq.
One Gateway Center Suite 2500
Newark, New Jersey 07102
Email: dgrantz@meyner.com
Direct: (973) 602-3466
DATED: June 20, 2024
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CERTIFICATION PURSUANT TO R. 1:38-7(C)
I 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).
MEYNER AND LANDIS, LLP
Attorneys for Plaintiff
Andrew Schumacher
By: /s/ David B. Grantz ________
David B. Grantz, Esq.
One Gateway Center Suite 2500
Newark, New Jersey 07102
Email: dgrantz@meyner.com
Direct: (973) 602-3466
DATED: June 20, 2024
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Preview
ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 1 of 12 Trans ID: LCV20241559314 MEYNER AND LANDIS LLP David B. Grantz, Esq. Filing Attorney No.: 042981996 One Gateway Center, Suite 2500 Newark, New Jersey 07102 973-602-3466 * Fax 973-624-0356 dgrantz@meyner.com Attorneys for Plaintiff Andrew Schumacher SUPERIOR COURT OF NEW JERSEY LAW DIVISION: ESSEX COUNTY DOCKET NO.: ANDREW SCHUMACHER, Plaintiff, Civil Action v. COMPLAINT JUDSON B. SCHUMACHER and NANCY B. SCHUMACHER Defendants. Plaintiff, Andrew Schumacher, by his attorneys Meyner and Landis, LLP, files the following Complaint against Defendants Judson B. Schumacher and Nancy B. Schumacher as follows: PARTIES 1. At times relevant hereto, Plaintiff, Andrew Schumacher (“Plaintiff”), is an individual residing at 736 N. Western Avenue, #395 Lake Forest, IL 60045. 2. Upon information and belief, Defendant, Judson B. Schumacher (“J. Schumacher”) is an individual residing at 57 White Oak Ridge, Short Hills, New Jersey 07078. ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 2 of 12 Trans ID: LCV20241559314 3. Upon information and belief, Defendant, Nancy B. Schumacher (“N. Schumacher”) is an individual residing at 57 White Oak Ridge, Short Hills, New Jersey 07078. (J. Schumacher and N. Schumacher are sometimes hereinafter referred to as “Defendants”). JURISDICTION AND VENUE 5. Venue is appropriate in this Court because Plaintiffs’ claims arise from transactions and occurrences in Essex County, New Jersey and Defendants reside in Essex County, New Jersey. FACTUAL BACKGROUND I. The First Loan 6. On December 9, 2014, Plaintiff agreed to lend Defendants $150,000 and extended a personal loan to Defendants on that date (the “First Loan”). 7. The First Loan was evidenced by a certain Promissory Note dated December 9, 2014 (the “First Promissory Note”). 8. Pursuant to the First Promissory Note, Plaintiff advanced $75,000 to Defendants on December 10, 2014, and then another $75,000 to Defendants on December 11, 2014. 9. Interest accrues on the outstanding indebtedness due on the First Promissory Note at a fixed interest rate of three percent (3%) per annum. 10. As set forth in the First Promissory Note, Defendants agreed to pay Plaintiff all principal and accrued interest due and payable three (3) years from the date of the First Promissory Note, or December 10, 2017. 2 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 3 of 12 Trans ID: LCV20241559314 11. Defendants did not pay Plaintiff the outstanding indebtedness under the First Promissory Note as agreed. II. The Second Loan 12. On August 18, 2015, Plaintiff agreed to lend Defendants another $150,000 and extended a second personal loan to Defendants on that date (the “Second Loan”). 13. The Second Loan was evidenced by a certain Promissory Note dated August 18, 2015 (the “Second Promissory Note”). 14. Pursuant to the Second Promissory Note, Plaintiff advanced $75,000 to Defendants on August 19, 2015, and then another $75,000 to Defendants on August 20, 2015. 15. Interest accrues on the outstanding indebtedness due on the Second Promissory Note at a fixed interest rate of three percent (3%) per annum. 16. As set forth in the Second Promissory Note, Defendants agreed to pay Plaintiff all principal and accrued interest due and payable two (2) years from the date of the Second Promissory Note, or August 18, 2017. 17. Defendants did not pay Plaintiff the outstanding indebtedness under the Second Promissory Note as agreed. III. The Third Loan 18. On or about June 1, 2016, Plaintiff agreed to lend Defendants another $30,000 and extended a third personal loan to Defendants on that date (the “Third Loan”). 3 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 4 of 12 Trans ID: LCV20241559314 19. The Third Loan was evidenced by a certain Promissory Note dated June 1, 2016 (the “Third Promissory Note”). 20. Pursuant to the Third Promissory Note, Plaintiff advanced $30,000 to Defendants on June 2, 2016. 21. Interest accrues on the outstanding indebtedness due on the Third Promissory Note at a fixed interest rate of three percent (3%) per annum. 22. As set forth in the Third Promissory Note, Defendants agreed to pay Plaintiff all principal and accrued interest due and payable on or before August 31, 2016. 23. Defendants did not pay Plaintiff the outstanding indebtedness under the Third Promissory Note as agreed. IV. Defendants’ Defaults and Amounts Due 24. An event of default occurred under the First Promissory Note due to Defendants’ failure to make the required payment of principal and interest due on the December 10, 2017, Maturity Date (the “First Loan Maturity Default”). 25. An event of default occurred under the Second Promissory Note due to Defendants’ failure to make the required payment of principal and interest due on the August 18, 2017 Maturity Date (the “Second Loan Maturity Default”). 26. An event of default occurred under the Third Promissory Note due to Defendants’ failure to make the required payment of principal and interest due on the August 31, 2016, Maturity Date (the “Third Maturity Default”). 4 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 5 of 12 Trans ID: LCV20241559314 27. The First Maturity Default, Second Maturity Default, and Third Maturity Default are collectively referred to as the “Stated Defaults”. 28. In March 2018, via email, Defendants acknowledged the amounts were still outstanding, but failed to make payments on the outstanding indebtedness. 29. On February 17, 2022, Plaintiff wrote to Defendants demanding that Defendants respond if they disputed the amounts, requesting a full accounting of the amounts due on each loan, and when Defendants would pay the outstanding amounts due. 30. On February 18, 2022, Defendants confirmed receipt of the February 17, 2022 letter/email and that they were in agreement with the dates, the amounts due and the interest charges. 31. On March 12, 2022, Defendants offered to repay the outstanding indebtedness due on the loans in $25,000 quarterly payments and if the $25,000 quarterly payments could not be maintained, then they would liquidate housing assets as their plan to repay the funds that they acknowledged owing to Plaintiff. 32. On March 17, 2022, Defendant began to repay the outstanding indebtedness with an initial $25,000 payment as they offered to do. 33. Payments continued to be made in $25,000 increments on June 6, 2022, August 15, 2022, November 15, 2022, and on February 17, 2023. 34. On May 15, 2023, Defendants made a $15,000 payment, rather than a $25,000 payment as offered. 5 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 6 of 12 Trans ID: LCV20241559314 35. On August 15, 2023, Defendants made a $10,000 payment rather than a $25,000 payment as offered. 36. On November 30, 2023, Defendants made a $15,000 payment rather than a $25,000 payment as offered. 37. On February 15, 2024, Defendants made a $10,000 payment rather than a $25,000 payment as offered. 38. By correspondence dated April 12, 2024, Plaintiff, through counsel, declared the Loans to be in default for failure to repay the amounts due and demanded full payment of the then outstanding balance due of Two Hundred Forty Thousand Two Hundred Fifty-Six and 94/100 ($240,256.04) Dollars. 39. On May 15, 2024, Defendants made a $25,000 payment and Plaintiff sent a reservation of rights letter on May 16, 2024 acknowledging receipt of the $25,000 payment and reserving all rights and remedies. 40. As of May 15, 2024, the outstanding principal balance due on the Loans was $216,121.64 with per diem interest accruing daily in the amount of $17.76 for May 15, 2024 and each day thereafter. FIRST COUNT (Breach of Contract – First Loan) 41. Plaintiff incorporates and re-alleges the facts and allegations set forth above as if fully set forth herein at length. 6 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 7 of 12 Trans ID: LCV20241559314 42. Plaintiff agreed to and did lend $150,000 to Defendants as evidenced by the First Promissory Note. 43. Pursuant to the First Promissory Note, Defendants agreed to repay Plaintiff $150,000 by December 10, 2017. 44. Plaintiff agreed to and did lend $150,000 to Defendants as evidenced by the Second Promissory Note. 45. Pursuant to the Second Promissory Note, Defendants agreed to repay Plaintiff $150,000 by August 18, 2017. 46. Plaintiff agreed to and did lend $30,000 to Defendants as evidenced by the Third Promissory Note. 47. Pursuant to the Third Promissory Note, Defendants agreed to repay Plaintiff $30,000 by August 31, 2016. 48. Defendants failed to repay the outstanding indebtedness due on (a) the First Promissory Note on or before December 10, 2017, (b) the Second Promissory Note on or before August 18, 2017, and (c) the Third Promissory Note on or before August 31, 2016. 49. In March 2018, Defendants acknowledged the indebtedness due under the First Promissory Note, the Second Promissory Note and the Third Promissory Note (collectively the “Notes’) and assured Plaintiff that the indebtedness would be paid in full. 50. In February 2022 and March 2022, Plaintiff further acknowledged the outstanding indebtedness due under the Notes, assured Plaintiff the outstanding indebtedness would be paid 7 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 8 of 12 Trans ID: LCV20241559314 and began to repay the outstanding indebtedness in sporadic incremental payments of $25,000, $15,000 and $10,000 quarterly from 2022 to 2024. 51. In April 2024, Plaintiff declared Defendants to be in default of the loans and demanded immediate payment of the outstanding balance due and owing, but Defendants failed to pay the outstanding balance. 52. As a direct and proximate result of Defendants’ failure to pay the Notes as agreed, Plaintiff is entitled to damages for breach of contract in the amount of the outstanding indebtedness due on the First Loan, the Second Loan and the Third Loan (collectively the “Loans”), plus interest accruing thereon. WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson B. Schumacher and Nancy B. Schumacher, jointly and severally, for: A. The outstanding principal sum of $216,121.64, together with accrued interest, and other allowed charges; B. Costs of suit and attorneys’ fees as allowed by law; and C. For such other relief as the Court deems appropriate. SECOND COUNT (Unjust Enrichment- First Loan) 53. Plaintiff incorporates and re-alleges the facts and all allegations set forth above as if fully set forth herein at length. 54. Defendants received and accepted the Loans from Plaintiff. 8 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 9 of 12 Trans ID: LCV20241559314 55. Defendants knew or had reason to know that Plaintiff expected to be repaid the money he lent them with interest. 56. Defendants acknowledged the indebtedness due in 2018 and 2022 and repeatedly ratified and reaffirmed their obligations to repay the indebtedness due under the Loans. 57. Plaintiff demanded repayment of the Loans, but despite Plaintiff’s demands, Defendants failed to pay the amounts owed within a reasonable time after such demand for payment. 58. Defendants are now indebted to Plaintiff in the total amount, as of May 15, 2024, of $216,121.64, plus interest and other allowed charges. WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson B. Schumacher and Nancy B. Schumacher, jointly and severally, for: A. The outstanding principal sum of $216,121.64, together with accrued interest, and other allowed charges; B. Costs of suit and attorneys’ fees as allowed by law; and C. For such other relief as the Court deems appropriate. THIRD COUNT (Collection on Account Stated) 59. Plaintiff incorporates and re-alleges the facts and all allegations set forth above as if fully set forth herein at length. 9 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 10 of 12 Trans ID: LCV20241559314 60. Plaintiff repeatedly notified Defendants of the balance due on the Loans. 61. Defendants did not and have not objected or disputed the amount due and owing to Plaintiff. WHEREFORE, Plaintiff Andrew Schumacher, demands judgment against Judson B. Schumacher and Nancy B. Schumacher, jointly and severally, for: A. The outstanding principal sum of $216,121.64, together with accrued interest, and other allowed charges on the Account Stated; B. Costs of suit and attorneys’ fees as allowed by law; and C. For such other relief as the Court deems appropriate. MEYNER AND LANDIS, LLP Attorneys for Plaintiff Andrew Schumacher By: /s/ David B. Grantz ________ David B. Grantz, Esq. One Gateway Center Suite 2500 Newark, New Jersey 07102 Email: dgrantz@meyner.com Direct: (973) 602-3466 DATED: June 20, 2024 10 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 11 of 12 Trans ID: LCV20241559314 CERTIFICATION The undersigned, attorneys for Plaintiff, Andrew Schumacher, hereby certifies in accordance with Rule 4:5-1 that the within action is not the subject of any other action or pending arbitration proceeding, nor is any other action or arbitration proceeding contemplated, the undersigned further certifies that there are no other parties which should be joined in this action. MEYNER AND LANDIS, LLP Attorneys for Plaintiff Andrew Schumacher By: /s/ David B. Grantz ________ David B. Grantz, Esq. One Gateway Center Suite 2500 Newark, New Jersey 07102 Email: dgrantz@meyner.com Direct: (973) 602-3466 DATED: June 20, 2024 11 ESX-L-004209-24 06/20/2024 11:19:58 AM Pg 12 of 12 Trans ID: LCV20241559314 CERTIFICATION PURSUANT TO R. 1:38-7(C) I 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). MEYNER AND LANDIS, LLP Attorneys for Plaintiff Andrew Schumacher By: /s/ David B. Grantz ________ David B. Grantz, Esq. One Gateway Center Suite 2500 Newark, New Jersey 07102 Email: dgrantz@meyner.com Direct: (973) 602-3466 DATED: June 20, 2024 12