New Jersey Lawyers' Fund for Client Protection
Richard J. Hughes Justice Complex
25 West Market Street, P.O. Box 961
Trenton, NJ 08625-0961
(609) 292-8008
Attorney for Plaintiff
CPF
____________________________________
NEW JERSEY LAWYERS’ FUND FOR : SUPERIOR COURT OF NEW JERSEY
CLIENT PROTECTION,
: LAW DIVISION
: MERCER COUNTY
Plaintiff,
:
: DOCKET NO.
v.
:
:
Civil Action
,
:
:
NOTICE OF MOTION FOR SUMMARY
Defendant.
:
JUDGMENT
TO:
Respondent, name and address
PLEASE TAKE NOTICE that on Friday, March 8, 2013, at 9 o'clock in the forenoon or as
soon thereafter as counsel may be heard, the undersigned attorney for the Plaintiff, New Jersey
Lawyers Fund for Client Protection, shall make application at the Mercer County Court at 175 South
Broad Street, Trenton, New Jersey, seeking an Order granting the Plaintiff Summary Judgment upon
the claims and relief sought in the Complaint, upon the following grounds
1)
There is no genuine issue as to any material fact and the Plaintiff is entitled to
Summary Judgment as a matter of law.
2)
Defendant
has failed to answer or to interpose any defense to the
Complaint in the time permitted.
PLEASE TAKE FURTHER NOTICE THAT PLAINTIFF shall rely on the Statement of
Material Facts, Summary Judgment Brief and Affidavit attached hereto, in support of its Motion.
PLEASE TAKE FURTHER NOTICE that oral argument is not requested unless timely
opposition is filed.
NEW JERSEY LAWYERS’ FUND
FOR CLIENT PROTECTION
_____________________________
Dated:
PROOF OF SERVICE
I certify that the original and one (1) copy of this Notice of Motion with supporting
documents were mailed to the Motions Clerk, Superior Court of New Jersey, Mercer County Court
House, 175 South Broad Street, P. O. Box 8068, Trenton, New Jersey 08650-0068 on
___________________.
I certify that one (1) copy of the Notice of Motion with supporting documents was mailed to
the Judge of the Superior Court of New Jersey, Mercer County Court House, 175 South Broad Street,
P. O. Box 8068, Trenton, New Jersey 08650-0068 on ______________________.
I also certify that one (1) copy of the Notice of Motion with supporting documents was
mailed to Defendant name and address, New Jersey, by regular and by certified mail, return receipt
requested to the address first noticed above on ___________________.
I am aware that if any of the foregoing statements are willfully false I am subject to
punishment.
_________________________
Dated:
K:\JoanneS\worddocs\SummaryJudgment\Rosenberg\Sum-Jud-Notice-of-Motion.doc