Professional Documents
Culture Documents
SCOTLAND -
BAUMANN 75 Livingston Avenue, Roseland, NJ 07068 (973) 622—1800
1
36730-022: 8023754
ii) any investigation conducted by Defendants or on behalf
iii) any and all claims of costs incurred for the water
Chamber;
professionals.
PRELIMINARY STATEMENT
alone 6, ll, 12, 14, 20, 25, 26, 27 and 28, 2018. The
on August
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August 25, 2018 break involved a 13—inch water main that flooded
is enough.
determine the cause of the repeated water main breaks and for
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the repair of the existing breaks that have jeopardized the
STATEMENT OF FACTS
LEGAL ARGUMENT
granted;
settled;
132—134.
See Gen. Elec. Co. v. Gem Vacuum Stores, 36 N.J. Super. 234, 237
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issuance of relief “are not to be looked upon as hard and fast
and sharply defined in scope; rather they are but factors, among
(App. Div. 1992) (stating that “[t]o the extent the factors
I RREPARABLE HARM
States, 321 U.S. 414, 440 (1944)1 recognized that courts, in the
1
Cited with by the Appellate Division in Waste
approval
Union County Utilities Authority, 399 N.J. Super.
Management v.
588, 520 (App. Div. 2008).
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Co. Fed’n, 300 U.S. 515, 552 (1937). The failure of
Ry. v.
Sys.
result.
required to protect its interests as a
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merits respecting the relief sought by this application is well
established.
CONCLUSION
this matter.
Respectfully submitted,
@6646 W/Véfifv/C743
William W. Northgrave
WWN/wpo
36730-022: 8023754
William W. Northgrave, Esq. (039201990)
MCMANIMON, SCOTLAND & BAUMANN, L.L.C.
INC.,
I
Defendant.
iii) any and all claims of costs incurred for the water
Chamber;
b. Within ten (10) days of the return of the
professionals;
this Order to Show Cause and the request for entry of injunctive
relief and of service by 2018.
proof ,
Please note further: if you do not file and serve an. Answer
Defendants. ORDER
36730—022: 8023724
1
including but not limited to record drawings (“as-builts”);
iii) any and all claims of costs incurred for the water
Chamber;
professionals;
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2
detailing: i) the scope of construction occurring on the
any and all claims of costs incurred for the water main
Chamber;
professionals;
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3
Hon. Jeffrey R. Jablonski, P.J.Ch.
( ) Opposed
( ) Unopposed
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4
William W. Northgrave, Esq. (039201990)
McMANIMON, SCOTLAND & BAUMANN, L.L.C.
75 Livingston Avenue, Second Floor
Roseland, New Jersey 07068
(973) 622-1800
Attorneys for Plaintiff,
CITY OF HOBOKEN
PARTIES
New Jersey, charged with ensuring the health, safety and welfare
of its residents.
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City pursuant to an agreement first entered into in 1994, as
subsequently amended.
this month on August 6, 11, 12, 14, 16, 20, 25, 26, 27 and
28, 2018.
the City.
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8. On Tuesday August 28, 2018, an 8-inch break caused
the City and threatened both the PATH System and NJ Transit.
2017.
breaks in 2018.
and August during the prior five years, there have been a
constant flooding.
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l4. Defendants, as operator of the water supply system
water main breaks and for the repair of the existing breaks
INJUNCTIVE RELIEF
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a. Provide to the City all studies, reports, plans,
iii) any and all claims of costs incurred for the water
Chamber;
professionals;
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d. Grant such other relief as the Court deems
WILLIAM W. NORTHGRAVE
WILLIAM W.
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arbitration contemplated. I am not aware of the names of any
DATED:
AugustZi , 2018
ByM/rw WILLIAM W. NORTHGRAVE
redacted from the documents now submitted to the Court, and will
WILLIAM W. NORTHGRAVE
36730-022: 8023735
VERIFICATION OF COMPLAINT
COUNTY OF HUDSON }
} SS
STATE OF NEW JERSEY }
for the City of Hoboken, being of full age and having been sworn
says:
CITY OF HOBOKEN
WQ-QAVWGgfi 6mm:
Je
knifer\G
fnzale§_J .
H
\a_./
Sworn and
subscribed to
before me this QflTH day
of August, 2018
DAISY AMADO
rvT‘
ID # 2405965
NCfiARYPUBUC
STATE OF NEW JERSEY
My Gommlsalun Expires March 22. 2021
36730-022: 802373.4
William W. Northgrave, Esq. (039201990)
MCMANIMON, SCOTLAND & BAUMANN, L.L.C.
75 Livingston Avenue, Second Floor
Roseland, New Jersey 07068
(973) 622—1800
Defendant.
FACSIMILE CERTIFICATION
By:
WILLIAM P. OPEL \
Dated: August 29, 2018
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