Chrysler Subpoenas Jenelle Embrey
SUBPOENA/SUBPOENA DUCES TECUM File No. MRS-L-3575-08
TO PERSON UNDER FOREIGN SUBPOENA
Commonwealth of Virginia VA CODE §§ 8.01-412.8—8.01-412.15; Rule 4:9
WARREN COUNTY Circuit Court
1 EAST MAIN STREET FRONT ROYAL, VA 22630
address of court
Deceased
THOMAS KLINE, ADMR SUSAN[MORRIS KUNE v.//in re: VICTORI A MORGAN-ALCALA, ET ALS
TO THE PERSON AUTHORIZED BY LAW TO SERVE THIS PROCESS:
You are commanded to summon
JENELLE EMBREY
Washington DC 20001
TO THE PERSON SUMMONED: You are commanded to [X] attend and give testimony at a deposition
[ ] produce the books, documents, records, electronically stored information, and tangible things designated and described below
SEE ATTACHED SUBPOENA AD TESTIFICANDUM & DUCES TECUM on November 14, 2013 at 10; 00 am at Front Royal, Virginia 22630
and to permit inspection and copying by the requesting party or someone acting in his or her behalf of the designated items in your possession, custody or control
permit inspection of the premises
at the following location
on ………………………………….
date and time
This subpoena is issued upon the request of the party named below
Loman Auto Group, Callahan & Fusco LLC
72 Eagle Rock Avenue, Suite 320
East Hanover New..Jersey 07936
form cc-1439 (master, page one of three) 07/09
The requesting party has submitted to this Clerk’s Office the foreign subpoena, copy attached, the terms of which are incorporated herein, and the written statement required by Virginia Code § 8.01-412.10.
The names, addresses and telephone numbers of all counsel of record in the proceeding to which the subpoena relates and of parties not represented by counsel are provided [ ] below [ ] on attached list.
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JENNIFER R, SIMS |
OCTOBER 25, 2013
RETURN OF SERVICE (see page three of this form)
FORM CC-I439 (MASTER, PAGE TWO OF THREE) 07/09
|X] This Subpoena/Subpoena Duces Tecum to Person Under Foreign Subpoena is being served by a private process server who must provide proof of service in accordance with Va. Code § 8.01-325.
TO the person authorized to serve this process: Upon execution, the return of this process shall be made to the Clerk of Court.
NAME: ……
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Tel. No. |
ADDRESS:.
PERSONAL SERVICE
Being unable to make personal service, a copy was delivered in the following manner:
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[ ] not found |
[ ] Delivered to family member (not temporary sojourner or guest) age 16 or older at usual place of abode of party named above after giving information of its purport. List name, age of recipient, and relation of recipient to party named above:
[ ] Posted on front door or such other door as appears to be the main entrance of usual place of abode, address _________________ listed above. (Other authorized recipient not found.)________________________________________________ ^________________________
………………………………………………………………………………………. , Sheriff
by …………………………………………………………………………………… , Deputy Sheriff
form cc-1439 (master, page three of three) 07/09
CALLAHAN & FUSCO, LLC 72 Eagle Rock Avenue, Suite 320 East Hanover, New Jersey 07936 (973)618-9770
Attorneys for Defendant LOMAN AUTO GROUP
THOMAS KLINE, as Administrator Ad Prosequendum of the Heirs at Law of SUSAN MORRIS KLINE (DECEASED), as Administrator of the ESTATE OF SUSAN MORRIS KLINE, and THOMAS KLINE, individually,
Plaintiffs,
SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MORRIS COUNTY
Docket No.: MRS-L-3575-08
Civil Action
v.
VICTORIA MORGAN-ALCALA, CARLOS ALCALA, NATALIE RAWLS, DAIMLER CHRYSLER-CORPORATION a/k/a CHRYSLER CORPORATION, LOMAN AUTO GROUP, CHRYSLER GROUP (for discovery purposes), JOHN DOES A through Z (names being fictitious), and ABC CORPORATIONS 1 through 100 (names being fictitious),
Defendants.
SUBPOENA AD TESTIFICANDUM & DUCES TECUM
THE STATE OF NEW JERSEY TO:
Jenelle Embrey
Washington, D.C. 20001
YOU ARE HEREBY COMMANDED pursuant to the New Jersey Rules of Court to attend and appear and give testimony at ******, Front Royal, Virginia 22630, on November 14, 2013, at 10:00 a.m. on the part of the defendant in the above-captioned matter and you are further commanded further to bring with you and produce at that time and place the books, papers, documents, and other tangible things described herein.
SPECIFIC REQUESTS
- Any and all correspondence, including email correspondence, or other documentation received from or sent to attorneys, parties, and or their experts involved in litigation arising out of motor vehicle accidents involving Jeep Grand Cherokee motor vehicles and Jenelle Embrey;
- Any and all documents or writings, including email correspondences, between Jenelle Embrey and any person, including attorney, or party, or expert, associated with the case of Kline, et al v. Alcala, et al.
- Any and all correspondence, including email correspondence, or other documentation received from or sent to the NHTSA to or from Jenelle Embrey concerning motor vehicle accidents involving Jeep Grand Cherokee motor vehicles;
- Any and all postings or writings of any kind placed by Jenelle Embrey on the internet; and
- Any and all documents possessed concerning a petition submitted by Jenelle Embrey to the NHTSA concerning Jeep Grand Cherokee motor vehicles.
The subpoenaed evidence shall not be produced or released until the date specified for the taking of the deposition. If you are notified that a motion to quash or any other written objection to the subpoena has been filed, you shall not produce or release the subpoenaed evidence until ordered to do so by the court or the release is consented to by all of the parties to the action.
Failure to appear according to the command of this Subpoena will subject your client, Jenelle Embrey, to a penalty, damages in a Civil Suit and punishment for contempt of Court.
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CALLAHAN & FUSCO, LLC
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Dated: October 18, 2013
/s/ Jennifer Perez
JENNIFER PEREZ, CLERK
CERTIFICATION OF SERVICE
I, Lucinda J, McLaughlin, of full age, being duly sworn, according to law and upon my oath, depose and say:
- I am an attorney with the law firm of Callahan & Fusco, LLC and assigned the handling of this action.
- On October 18, 2013,1 served, via regular mail, a copy of the within Subpoena ad
Testificandum and Subpoena Duces Tecum to:
Angel DeFilippo, Esq.
Grieco, Oates & DeFilippo, LLC 414 Eagle Rock Avenue, Suite 200 West Orange, New Jersey 07052
James T. Gill, Esq.
Leary, Bride, Tinker & Moran 7 Ridgcdalc Avenue Cedar Knolls, New Jersey 07927
- I certify that the foregoing statements made by me are true. I am aware that if any
of the foregoing statements are willfully false, I am subject to punishment. Dated: October 18, 2013
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Patrick J. Hermesmann, Esq. Law Offices of Terkowitz & Hermesmann 400 Atrium Drive Somerset, New Jersey 08875 |
LUCINDA J. fvlCLAUdrHLIN
Author: Jenelle Embrey
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