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A newly filed lawsuit faults the Township of Jackson, the Jackson Township Municipal Utilities Authority (JTMUA), and the County of Ocean for failing to adequately warn drivers of road work which led to a car crash, FAA News has learned.

According to the Complaint just filed in New Jersey Superior Court in Ocean County by Attorney Jonathan S. Fabricant Esq. of Bathgate, Wegener & Wolf:

On November 29, 2022, Jackson resident Robert J. Thomas III was driving eastbound on North Cooks Bridge Road.

Angel X. Cuadrado was driving a vehicle owned by P&A Construction Inc. He was also driving eastbound on North Cooks Bridge Road, and he caused a collision with Mr. Thomas.

Mr. Cuadrado had a duty to operate his vehicle in a careful manner so as to avoid colliding with other motor vehicles lawfully on the roadway.

However, he negligently operated his motor vehicle in such a careless and negligent manner so as to cause a collision. In doing so, he failed to maintain and keep his motor vehicle under due and proper control; failed to observe oncoming traffic; failed to yield to Mr. Thomas's vehicle, and generally operated, maintained, and controlled his vehicle in a dangerous and reckless manner.

Additionally, P&A Construction knew that Mr. Cuadrado had access to use their vehicle, and they failed to exercise reasonable care in preventing Mr. Cuadrado's negligent and reckless actions.

In addition, the suit contends that "the Township, MUA, and/or County" are liable as they were supervisors of a construction project taking place at or near North Cooks Bridge Road and Willow Drive and they negligently failed to properly supervise the construction area in that they:

• Did not post advisory signs on or near North Cooks Bridge Road;

• Failed to give any notice of said construction;

• Failed to place flags, markers or any warnings that said the construction was occuring;

• Failed to properly caution people that the construction was occuring

• Failed to properly supervise the contractor and their employees hired for the construction project

As a direct and proximate result of the Township, MUA, and County's negligent supervision of Mr. Cuadrado and P&A Construction, they allowed a dangerous and hazardous condition to exist.

As a direct and proximate result of the negligence of all the defendants, Mr. Thomas was caused to sustain serious internal and external injuries; was caused to sustain serious mental pain and suffering, and emotional distress; and was caused to suffer other great losses; including, but not limited to permanent injuries which significantly impact his health and activities.

The Complaint demands judgement against Mr. Cuadrado, P&A Construction, Township of Jackson, the Jackson Township Municipal Utilities Authority, and the County of Ocean, individually, jointly, severally and/or in the alternative, for damages, attorney fees, together with interest and costs of suit and for such other relief as the Court may deem equitable and just.

The parties have 35 days from when served the Complained to formulate an Answer to the Complaint.

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