Preview
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg1of8 Trans ID: LCV20241592634
GREENBERG MINASIAN, LLC
80 Main Street
West Orange, New Jersey 07052
(973)325-7711
LAWRENCE D. MINASIAN - 034211994
Attorneys for Plaintiff(s)
Plaintiff(s)
RUTH SEJOUR SUPERIOR COURT OF NEW JERSEY
LAW DIVISION : ESSEX COUNTY
Docket No. ESX-L-
VS.
Defendant(s)
CIVIL ACTION
JUNIOR SACTA, JUNIOR FERNANDO
SACTA LEMA, MARTHA
CHAGMANACHACHA, JOHN DOES
I-XX, Fictitious Persons and ABC, INC.
I-X, Fictitious Corporations/Companies COMPLAINT AND JURY DEMAND
WITH DISCOVERY REQUESTS
Plaintiff, Ruth Sejour, residing at 258 Berkeley Avenue, Bloomfield, New Jersey, by way of Complaint
against the Defendants, says:
FIRST COUNT
On or about July 2, 2022, the Plaintiff, Ruth Sejour, was a driver of a vehicle traveling
northbound on North Grove Street in East Orange, New Jersey approaching the intersection
with Park Avenue.
At the same time and place, the Defendants Martha Chagmanachacha, John Does I-X,
fictitious persons, and/or ABC, Inc. I-X, fictitious corporations/companies, were the owners
of a vehicle operated by Defendants Junior Sacta, Junior Fernando Sacta Lema, and/or John
Does XI-XX, fictitious persons. That vehicle was traveling eastbound on Park Avenue, East
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 2of8 Trans ID: LCV20241592634
Orange, New Jersey, approaching the intersection with North Grove Street.
Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI-XX, fictitious
persons, were the employees, agents and/or servants of Defendants Martha Chagmanachacha,
John Does I-X, fictitious persons, and/or ABC, Inc. I-X, fictitious corporations/companies,
and were operating this vehicle at Defendants Martha Chagmanachacha, John Does I-X,
fictitious persons, and/or ABC, Inc. I-X’s, fictitious corporations/companies’ direction.
The Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI-XX,
jointly, severally and in the alternative did so recklessly, carelessly and negligently operate
their vehicle by failing to stop at a red light, yield to Plaintiff who had the right of way, and
then striking Plaintiff's vehicle.
Defendants Martha Chagmanachacha, John Does I-X, fictitious persons, and/or ABC, Inc.
I-X’s, fictitious corporations/companies, did so recklessly, carelessly and negligently entrust
their vehicle to Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI-
XX, so as to cause this collision, and did so recklessly, carelessly and negligently maintain
their vehicle so as to allow this collision to occur.
As a direct and proximate result of the Defendants' negligence, the Plaintiff sustained
personal injuries, which resulted in permanent injuries, which have not healed to function
normally and will not heal to function normally with further medical treatment.
Asa further result of the Defendants’ negligence, Plaintiff
has incurred and will continue to
incur expenses for doctors, hospital and other medical treatment for her injuries, and is
responsible for outstanding medical bills and medical liens. Plaintiff has also incurred
property damage and costs for rental/replacement vehicles and storage fees as a result of
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 3of8 Trans ID: LCV20241592634
Defendants’ negligence. In addition, Plaintiff has incurred and will continue to incur lost
wages and income, and has been disabled and unable to perform her usual functions and has
been caused and will be caused great pain and suffering, to her great loss and damage.
WHEREFORE, Plaintiff Ruth Sejour demands judgment against all Defendants for damages, interest
and costs of suit.
GREENBERG MINASIAN, LLC
Attorneys for Plaintiff
a
a = —— a
Dated: June 25, 2024 eee ESQ.
JURY DEMAND
Plaintiff demands trial by jury as to all issues involved herein.
GREENBERG MINASIAN, LLC
Attorneys for Plaintiff. ——
Dated: June 25, 2024 LAWRENCE D. MINASIAN, ESQ.
DESIGNATION OF TRIAL COUNSEL
Pursuant to R.4:25-4, Lawrence D. Minasian is hereby designated as Trial Counsel of this matter.
REQUEST FOR PRODUCTION OF DOCUMENTS
1 Any and all statements made by any party to this lawsuit, whether written or oral, including
any co-plaintiff(s) or co-defendant(s), their agents, representatives or employees concerning the action or
subject matter previously made by the Plaintiff pursuant to R.4:10-2(c). For the purposes of this rule, a
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg4of8 Trans ID: LCV20241592634
statement previously made is (1) a written statement signed or otherwise adopted or approved by the person
making it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which
is a substantially verbatim recital of an oral statement by the person making it and contemporaneously
recorded.
2. Any and all statements made by any witnesses to the events described in all of the paragraphs
of Plaintiffs Complaint. A statement made is (1) a written statement signed or otherwise adopted or
approved by the person making it; or (2) a stenographic, mechanical, electrical, or other recording, or a
transcription thereof, which is a substantially verbatim recital of an oral statement by the person making it
and contemporaneously recorded.
3 Any and all statements made by any person other than defendant(s) which relate or refer in
any way to the incident described in Plaintiff's Complaint. A statement made is (1) a written statement
signed or otherwise adopted or approved by the person making it; or (2) a stenographic, mechanical,
electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital ofan oral
statement by the person making it and contemporaneously recorded.
4 Any and all written reports including all notes, first drafts or previous versions of any report
rendered by Defendant's proposed expert witnesses including, but not limited to, any medical expert
witnesses intended or not intended to be called at the time of trial concerning the action or subject matter
previously made by the Plaintiff, pursuant to R.4:10-2(d), et seq. For the purposes of this rule, a statement
previously made is (1) a written statement signed or otherwise adopted or approved by the person making
it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a
substantially verbatim recital ofan oral statement by the person making it and contemporaneously recorded.
5 Any and all books, treatises, commentaries, reports, statutes, codes, ordinances, rules,
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regulations or other published documents referred to and utilized by or relied upon by any expert witness
whom Defendant(s) intend(s) to call at trial.
6 Any and all blueprints, charts, diagrams, drawings, graphs, maps, plats, plans, photographs,
models or other visual reproductions of any objects, place or thing prepared or utilized by, referred to or
relied upon by any expert witnesses whom Defendant(s) intend(s) to call at time of trial.
7. A photostatic copy of any photographs or surveys of the scene of the accident or of any
objects or persons involved therein whether in the possession of the Defendant, the Defendant's attorneys
or the possession of any representatives of the Defendant's insurance carriers.
8 A copy of any and all written reports or summaries of oral reports, as well as a copy of the
curriculum vitae, of any and all experts that have supplied reports to Defendant's attorney, whether or not
he or she is expected to testify as per R.4:10-2(d)(1).
9 A copy of any and all hospital and medical records regarding any medical treatment received
by Plaintiff which is alleged to relate to any injuries sustained as a result of any prior or subsequent
accidents, disease or illness to those alleged in the Complaint.
10. The results of any consumer index bureau or other similar such reporting agency which
records any prior or subsequent insurance claims, worker's compensation claims or other personal injury
claim relative to the Plaintiff(s) in this action.
11. All other documents upon which you intend to rely at the time of trial.
12. A copy of the entire investigation file, minus any privileged materials, including but not
limited to copies of any and all statements of all parties and all photographs of the accident scene or
automobiles involved in the collision.
13. A copy of your entire property damage file, minus any privileged information, including
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copies ofany and all property damage estimates, total loss reports, and correspondence to your insured or
Plaintiff, and photographs of the loss or accident scene.
14, A copy of Defendant’s cell phone bill and statement, including the name, address and account
number for the cell phone provider, which was in effect on the date of the accident, as well as any billing
statement covering that period of time.
15. All maintenance records for Defendant’s vehicle involved in the accident set forth in the
complaint from July 20, 2020 to December 31, 2022, including but not limited to an repairs or replacements
of the brakes for the vehicle.
DEMAND FOR ANSWERS TO INTERROGATORIES
DEMAND is hereby made of the Defendant(s) for certified answers to Uniform Interrogatories Form
C and Form C(1), contained in Appendix II of the Rules of Court, pursuant to R. 4:17-1(b)(ii) within the
time prescribed by the Rules of Court, as well as answers to the following Supplemental Interrogatories.
1 Describe in detail, the position of the vehicles when they came to rest, setting forth whether
any of the vehicles were moved from that position, before the police arrived upon the scene,
where the vehicle was moved to, and by whom the vehicle was moved.
State whether the police arrived upon the scene of the accident, setting forth whether you
gave a statement to the police as to the manner of the happening of the accident, what you
told the police, whether your statement appears in the police report, whether it is complete
and accurate, and any inaccuracies or omissions the report may contain.
State whether there were any obstructions or impediments at or near the scene of the accident
that interfered with the visual observations of the drivers involved in the accident fully
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg7of8 Trans ID: LCV20241592634
setting forth the location and size of the obstruction and manner in which they interfered with
vision.
Provide the cell phone number, cell phone carrier, and the name, address and account number
for this cell phone account for the cellular phone Defendant was using during the time period
which covered the date of the accident.
State whether the brakes of the vehicle owned or operated by you were applied at any time
prior to impact setting forth the distance in feet from the point of impact you first applied
your brakes and the length of tire or scuff marks caused by your vehicle.
State with particularity what you did to avoid the collision.
Did the operator of your vehicle consume any drugs, medication or alcoholic beverages
within the six hour period immediately preceding the happening of the accident referred to
in the Complaint setting forth the type of drugs, medication or alcoholic beverages and the
time and place each was consumed.
State with regard to the vehicle involved, either owned or operated by you at the time of the
alleged accident the make, model, year, license plate number, registration number and date
when said vehicle was last inspected prior to the alleged accident.
Set forth the destination of your motor vehicle at the time of the accident complained of and
the location where the driver of your motor vehicle had last entered said motor vehicle prior
to the accident alleged in the Complaint.
10. State whether your vehicle, (i.e. owned, operated or under your control), was damaged in the
alleged accident complained of in the Complaint, setting forth whether the vehicle was
repaired, the cost of repairs, the person or persons performing such repairs, whether an
ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 8of8 Trans ID: LCV20241592634
estimate for damages was prepared, the name of the person or persons who prepared such
estimate and attach a true copy of such estimate and bill for such repairs hereto.
CERTIFICATION
I hereby certify that this matter is not the subject of any other action pending in any Court or a
pending Arbitration proceeding, nor is any other action or Arbitration contemplated. All parties known to
Plaintiffs decedent, who should have been joined in this action have been joined.
GREENBERG MINASIAN, LLC
Attorneys for Plaintiff
_—
Dated: June 25, 2024 ENCE D. MINASIAN, ESQ.
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ESX-L-004320-24 06/25/2024 1:39:51 PM Pg1of8 Trans ID: LCV20241592634 GREENBERG MINASIAN, LLC 80 Main Street West Orange, New Jersey 07052 (973)325-7711 LAWRENCE D. MINASIAN - 034211994 Attorneys for Plaintiff(s) Plaintiff(s) RUTH SEJOUR SUPERIOR COURT OF NEW JERSEY LAW DIVISION : ESSEX COUNTY Docket No. ESX-L- VS. Defendant(s) CIVIL ACTION JUNIOR SACTA, JUNIOR FERNANDO SACTA LEMA, MARTHA CHAGMANACHACHA, JOHN DOES I-XX, Fictitious Persons and ABC, INC. I-X, Fictitious Corporations/Companies COMPLAINT AND JURY DEMAND WITH DISCOVERY REQUESTS Plaintiff, Ruth Sejour, residing at 258 Berkeley Avenue, Bloomfield, New Jersey, by way of Complaint against the Defendants, says: FIRST COUNT On or about July 2, 2022, the Plaintiff, Ruth Sejour, was a driver of a vehicle traveling northbound on North Grove Street in East Orange, New Jersey approaching the intersection with Park Avenue. At the same time and place, the Defendants Martha Chagmanachacha, John Does I-X, fictitious persons, and/or ABC, Inc. I-X, fictitious corporations/companies, were the owners of a vehicle operated by Defendants Junior Sacta, Junior Fernando Sacta Lema, and/or John Does XI-XX, fictitious persons. That vehicle was traveling eastbound on Park Avenue, East ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 2of8 Trans ID: LCV20241592634 Orange, New Jersey, approaching the intersection with North Grove Street. Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI-XX, fictitious persons, were the employees, agents and/or servants of Defendants Martha Chagmanachacha, John Does I-X, fictitious persons, and/or ABC, Inc. I-X, fictitious corporations/companies, and were operating this vehicle at Defendants Martha Chagmanachacha, John Does I-X, fictitious persons, and/or ABC, Inc. I-X’s, fictitious corporations/companies’ direction. The Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI-XX, jointly, severally and in the alternative did so recklessly, carelessly and negligently operate their vehicle by failing to stop at a red light, yield to Plaintiff who had the right of way, and then striking Plaintiff's vehicle. Defendants Martha Chagmanachacha, John Does I-X, fictitious persons, and/or ABC, Inc. I-X’s, fictitious corporations/companies, did so recklessly, carelessly and negligently entrust their vehicle to Defendants Junior Sacta, Junior Fernando Sacta Lema and/or John Does XI- XX, so as to cause this collision, and did so recklessly, carelessly and negligently maintain their vehicle so as to allow this collision to occur. As a direct and proximate result of the Defendants' negligence, the Plaintiff sustained personal injuries, which resulted in permanent injuries, which have not healed to function normally and will not heal to function normally with further medical treatment. Asa further result of the Defendants’ negligence, Plaintiff has incurred and will continue to incur expenses for doctors, hospital and other medical treatment for her injuries, and is responsible for outstanding medical bills and medical liens. Plaintiff has also incurred property damage and costs for rental/replacement vehicles and storage fees as a result of ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 3of8 Trans ID: LCV20241592634 Defendants’ negligence. In addition, Plaintiff has incurred and will continue to incur lost wages and income, and has been disabled and unable to perform her usual functions and has been caused and will be caused great pain and suffering, to her great loss and damage. WHEREFORE, Plaintiff Ruth Sejour demands judgment against all Defendants for damages, interest and costs of suit. GREENBERG MINASIAN, LLC Attorneys for Plaintiff a a = —— a Dated: June 25, 2024 eee ESQ. JURY DEMAND Plaintiff demands trial by jury as to all issues involved herein. GREENBERG MINASIAN, LLC Attorneys for Plaintiff. —— Dated: June 25, 2024 LAWRENCE D. MINASIAN, ESQ. DESIGNATION OF TRIAL COUNSEL Pursuant to R.4:25-4, Lawrence D. Minasian is hereby designated as Trial Counsel of this matter. REQUEST FOR PRODUCTION OF DOCUMENTS 1 Any and all statements made by any party to this lawsuit, whether written or oral, including any co-plaintiff(s) or co-defendant(s), their agents, representatives or employees concerning the action or subject matter previously made by the Plaintiff pursuant to R.4:10-2(c). For the purposes of this rule, a ESX-L-004320-24 06/25/2024 1:39:51 PM Pg4of8 Trans ID: LCV20241592634 statement previously made is (1) a written statement signed or otherwise adopted or approved by the person making it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement by the person making it and contemporaneously recorded. 2. Any and all statements made by any witnesses to the events described in all of the paragraphs of Plaintiffs Complaint. A statement made is (1) a written statement signed or otherwise adopted or approved by the person making it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement by the person making it and contemporaneously recorded. 3 Any and all statements made by any person other than defendant(s) which relate or refer in any way to the incident described in Plaintiff's Complaint. A statement made is (1) a written statement signed or otherwise adopted or approved by the person making it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital ofan oral statement by the person making it and contemporaneously recorded. 4 Any and all written reports including all notes, first drafts or previous versions of any report rendered by Defendant's proposed expert witnesses including, but not limited to, any medical expert witnesses intended or not intended to be called at the time of trial concerning the action or subject matter previously made by the Plaintiff, pursuant to R.4:10-2(d), et seq. For the purposes of this rule, a statement previously made is (1) a written statement signed or otherwise adopted or approved by the person making it; or (2) a stenographic, mechanical, electrical, or other recording, or a transcription thereof, which is a substantially verbatim recital ofan oral statement by the person making it and contemporaneously recorded. 5 Any and all books, treatises, commentaries, reports, statutes, codes, ordinances, rules, ESX-L-004320-24 06/25/2024 1:39:51 PM Pg5of8 Trans ID: LCV20241592634 regulations or other published documents referred to and utilized by or relied upon by any expert witness whom Defendant(s) intend(s) to call at trial. 6 Any and all blueprints, charts, diagrams, drawings, graphs, maps, plats, plans, photographs, models or other visual reproductions of any objects, place or thing prepared or utilized by, referred to or relied upon by any expert witnesses whom Defendant(s) intend(s) to call at time of trial. 7. A photostatic copy of any photographs or surveys of the scene of the accident or of any objects or persons involved therein whether in the possession of the Defendant, the Defendant's attorneys or the possession of any representatives of the Defendant's insurance carriers. 8 A copy of any and all written reports or summaries of oral reports, as well as a copy of the curriculum vitae, of any and all experts that have supplied reports to Defendant's attorney, whether or not he or she is expected to testify as per R.4:10-2(d)(1). 9 A copy of any and all hospital and medical records regarding any medical treatment received by Plaintiff which is alleged to relate to any injuries sustained as a result of any prior or subsequent accidents, disease or illness to those alleged in the Complaint. 10. The results of any consumer index bureau or other similar such reporting agency which records any prior or subsequent insurance claims, worker's compensation claims or other personal injury claim relative to the Plaintiff(s) in this action. 11. All other documents upon which you intend to rely at the time of trial. 12. A copy of the entire investigation file, minus any privileged materials, including but not limited to copies of any and all statements of all parties and all photographs of the accident scene or automobiles involved in the collision. 13. A copy of your entire property damage file, minus any privileged information, including ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 6of8 Trans ID: LCV20241592634 copies ofany and all property damage estimates, total loss reports, and correspondence to your insured or Plaintiff, and photographs of the loss or accident scene. 14, A copy of Defendant’s cell phone bill and statement, including the name, address and account number for the cell phone provider, which was in effect on the date of the accident, as well as any billing statement covering that period of time. 15. All maintenance records for Defendant’s vehicle involved in the accident set forth in the complaint from July 20, 2020 to December 31, 2022, including but not limited to an repairs or replacements of the brakes for the vehicle. DEMAND FOR ANSWERS TO INTERROGATORIES DEMAND is hereby made of the Defendant(s) for certified answers to Uniform Interrogatories Form C and Form C(1), contained in Appendix II of the Rules of Court, pursuant to R. 4:17-1(b)(ii) within the time prescribed by the Rules of Court, as well as answers to the following Supplemental Interrogatories. 1 Describe in detail, the position of the vehicles when they came to rest, setting forth whether any of the vehicles were moved from that position, before the police arrived upon the scene, where the vehicle was moved to, and by whom the vehicle was moved. State whether the police arrived upon the scene of the accident, setting forth whether you gave a statement to the police as to the manner of the happening of the accident, what you told the police, whether your statement appears in the police report, whether it is complete and accurate, and any inaccuracies or omissions the report may contain. State whether there were any obstructions or impediments at or near the scene of the accident that interfered with the visual observations of the drivers involved in the accident fully ESX-L-004320-24 06/25/2024 1:39:51 PM Pg7of8 Trans ID: LCV20241592634 setting forth the location and size of the obstruction and manner in which they interfered with vision. Provide the cell phone number, cell phone carrier, and the name, address and account number for this cell phone account for the cellular phone Defendant was using during the time period which covered the date of the accident. State whether the brakes of the vehicle owned or operated by you were applied at any time prior to impact setting forth the distance in feet from the point of impact you first applied your brakes and the length of tire or scuff marks caused by your vehicle. State with particularity what you did to avoid the collision. Did the operator of your vehicle consume any drugs, medication or alcoholic beverages within the six hour period immediately preceding the happening of the accident referred to in the Complaint setting forth the type of drugs, medication or alcoholic beverages and the time and place each was consumed. State with regard to the vehicle involved, either owned or operated by you at the time of the alleged accident the make, model, year, license plate number, registration number and date when said vehicle was last inspected prior to the alleged accident. Set forth the destination of your motor vehicle at the time of the accident complained of and the location where the driver of your motor vehicle had last entered said motor vehicle prior to the accident alleged in the Complaint. 10. State whether your vehicle, (i.e. owned, operated or under your control), was damaged in the alleged accident complained of in the Complaint, setting forth whether the vehicle was repaired, the cost of repairs, the person or persons performing such repairs, whether an ESX-L-004320-24 06/25/2024 1:39:51 PM Pg 8of8 Trans ID: LCV20241592634 estimate for damages was prepared, the name of the person or persons who prepared such estimate and attach a true copy of such estimate and bill for such repairs hereto. CERTIFICATION I hereby certify that this matter is not the subject of any other action pending in any Court or a pending Arbitration proceeding, nor is any other action or Arbitration contemplated. All parties known to Plaintiffs decedent, who should have been joined in this action have been joined. GREENBERG MINASIAN, LLC Attorneys for Plaintiff _— Dated: June 25, 2024 ENCE D. MINASIAN, ESQ.