Brian Sarratt v. Nj Pliga

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 8, 2024
DocketA-0786-22
StatusUnpublished

This text of Brian Sarratt v. Nj Pliga (Brian Sarratt v. Nj Pliga) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Sarratt v. Nj Pliga, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0786-22

BRIAN SARRATT,

Plaintiff-Appellant,

v.

NJ PLIGA,

Defendant-Respondent. ________________________

Submitted December 20, 2023 – Decided January 8, 2024

Before Judges Accurso and Walcott-Henderson.

On appeal from the Superior Court of New Jersey, Law Division, Union County, L-3903-21.

John J. Pisano, attorney for appellant.

Flanagan, Barone & O'Brien, LLC, attorneys for respondent (Michelle Mary O'Brien, of counsel and on the brief; Frank Joseph Morano, on the brief).

PER CURIAM

Brian Sarratt appeals from orders dismissing his complaint (and denying

reconsideration) against the New Jersey Property-Liability Insurance Guaranty Association (PLIGA), the statutory administrator of the Unsatisfied Claim and

Judgment Fund (UCJF or Fund), pursuant to Rule 4:6-2(e) for failure to

establish he was a qualified claimant under N.J.S.A. 39:6-62 and to comply

with the notice provisions of N.J.S.A. 39:6-65. We affirm.

Plaintiff was riding a bicycle in Elizabeth on a rainy night in October

2021, when a small, white hatchback turned into him, knocking him to the

ground. The car didn't stop. Police and paramedics responded to the scene.

The police completed an accident report, documenting plaintiff's report that a

hit-and-run driver making a left turn collided with the front wheel of his

bicycle. The report did not note any witnesses to the accident. Plaintiff

declined medical attention and "limped" the few blocks home, his bike being

unrideable.

Plaintiff promptly retained counsel who ten days later faxed PLIGA a

letter attaching the police report and notes from a medical provider, requesting

"all necessary forms, so as to arrange for the processing of this claim." The

following week, counsel filed a complaint on plaintiff's behalf asserting his

eligibility for bodily injury uninsured motorist benefits. Counsel, however, did

A-0786-22 2 not file a notice of intent to make a claim on plaintiff's behalf within the 180

days permitted by N.J.S.A. 39:6-65.1

Counsel for PLIGA wrote to plaintiff's counsel on December 16, 2021,

thirty days after the complaint was filed, and nearly seven weeks after the

accident, requesting

the requisite documentation in support of your client's application for benefits including:

• Proof of residency on the date of loss

• Notice of Intention

• Affidavit of No Insurance

• Certification of Medicare Eligibility; and

• Application for PIP benefits.

1 N.J.S.A. 39:6-65 provides in pertinent part:

Any qualified person . . . who suffers damages resulting from bodily injury . . . arising out of the ownership, maintenance or use of a motor vehicle in this State on or after April 1, 1955, and whose damages may be satisfied in whole or in part from the fund, shall . . . within 180 days after the accident, as a condition precedent to the right thereafter to apply for payment from the fund, give notice to the association, the form and contents of which shall be prescribed by the association, of his intention to make a claim thereon for such damages if otherwise uncollectible ....

A-0786-22 3 Plaintiff's counsel did not respond to that letter and did not submit the

requisite documents. Plaintiff did, however, provide answers to interrogatories

in mid-February 2022, disclosing his address, but not his social security

number, and certifying he lived alone and that there were no witnesses to the

accident. PLIGA's counsel wrote plaintiff's counsel again on April 5, 2022,

renewing her request for proof of plaintiff's residency and "plaintiff's

documents in support of UCJF eligibility." PLIGA's counsel received no

response to that letter either. The 180-day time period for notice expired on

April 27, 2022, without plaintiff's counsel filing the necessary documents.

PLIGA deposed plaintiff on May 12, 2022. At his deposition, plaintiff

provided counsel his social security number. He also confirmed his address,

testifying it was an apartment belonging to a friend where he'd lived for two

years — contrary to his interrogatory response that he lived alone. He reported

his friend owned a Cadillac Escalade, which was insured on the date of the

accident. In response to a question from PLIGA's counsel about a motorcycle

and a black Lexus parked at his home, plaintiff responded that the Lexus

belonged to his friend and the motorcycle belonged to a friend of his friend.

Although plaintiff certified in his answers to interrogatories that there

were no witnesses to the accident, he testified at his deposition there were two

A-0786-22 4 witnesses. One, a woman who stopped to help and another, a mechanic at a

garage "directly across" from where plaintiff was hit, who assisted him to a

chair in the garage and called the police. Plaintiff did not get either of their

names, describing both as Hispanic. 2

Following the deposition, PLIGA's counsel wrote to plaintiff's counsel

on June 8, 2022, referencing her letter of April 5, and noting she had yet to

receive proof of plaintiff's residence or "plaintiff's documents in support of

UCJF eligibility." Counsel enclosed with that letter the PLIGA forms for an

affidavit in support of UCJF eligibility, certification of Medicare eligibility,

notice of intention to make a claim, and an application for PIP benefits, asking

counsel to supply the completed documents "forthwith," and that failure to do

so within ten days would result in the filing of a motion. Plaintiff's counsel

did not respond to that letter.

Over two months later, PLIGA filed its motion to dismiss plaintiff's

complaint for failure to comply with the notice provisions of N.J.S.A. 39:6-65.

2 Plaintiff also testified at his deposition that he'd used the name Keith Sarratt as "an alias" in the past. We note this not to suggest any fraud or abuse on plaintiff's part but to underscore the importance to PLIGA of the timely rece ipt of information, including a claimant's social security number, to allow it to conduct an effective investigation of the claim. See Giacobbe v. Gassert, 29 N.J. 421, 425 (1959) (noting the statutory "notice is designed to afford a timely inquiry and thus to safeguard the fund against fraud and imposition"). A-0786-22 5 Two days later, plaintiff's counsel responded with an executed affidavit in

support of UCJF eligibility, an executed notarized PLIGA claim form, an

executed certification of Medicare eligibility, a notice of intention to make a

claim, and a completed application for PIP benefits. Plaintiff did not include

an affidavit of no insurance. PLIGA argued plaintiff's failure to supply an

affidavit stating he was without insurance on the date of the accident rendered

him disqualified for benefits under N.J.S.A. 39:6-62, and the eligibility

documents he supplied in response to the motion were tendered well beyond

the 180-day limit for notice under N.J.S.A. 39:6-65. Plaintiff countered that he

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Related

Douglas v. Harris
173 A.2d 1 (Supreme Court of New Jersey, 1961)
Jimenez v. Baglieri
704 A.2d 1285 (Supreme Court of New Jersey, 1998)
Myers v. Cave
150 A.2d 269 (New Jersey Superior Court App Division, 1959)
Szczesny v. Vasquez
177 A.2d 47 (New Jersey Superior Court App Division, 1962)
Giacobbe v. Gassert
149 A.2d 214 (Supreme Court of New Jersey, 1959)

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