CERTIFICATION-NO OTHER ACTION TAKEN (R. 4:5-1)
The plaintiffs hereby certify that the matter in controversy is not the subject of any other action pending in any court and is likewise not the subject of any pending arbitration proceeding. The plaintiffs further certify that they have no knowledge of any contemplated action or arbitration proceeding which is contemplated regarding the subject matter of this action. The plaintiffs further certify that they are not aware of any other parties who should be joined in this action.
DEMAND FOR JURY TRIAL
The plaintiffs hereby demand trial by jury as to all issues in the above matter.
DEMAND FOR DISCOVERY OF INSURANCE COVERAGE
Pursuant to New Jersey Court Rule 4:10-2(b), demand is made that defendants disclose to plaintiff's attorney whether or not there are any insurance agreements or policies under which any person or firm carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action or indemnify or reimburse for payments made to satisfy the judgment and provide plaintiff's attorney with true copies of those insurance agreements or policies, including, but not limited to, any and all declaration sheets. This demand shall include and cover not only primary coverage, but also any and all excess, catastrophe and umbrella policies.
DESIGNATION OF TRIAL ATTORNEY
In accordance with R. 4:25-4, Dan Martin is hereby designated as trial counsel for plaintiffs in the above matter.
Dated: January 23, 2008
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Dan Martin
Attorney For Plaintiffs
