Notice of Motion for Judgment
Attorney ID #029422005
Law Offices of Joseph Basso, Esquire
126 White Horse Pike
Haddon Heights, NJ 08035
(856)546-4644
(fax) (856) 546-4711
jbasso@bassolawoffices.com
Attorney for Plaintiff
MICHAEL MORRISSEY
SAMANTHA MORRISSEY : SUPERIOR COURT OF
: NEW JERSEY
Plaintiffs : LAW DIVISION
Vs.
: CAMDEN COUNTY
AUTOMSMART OF PALYMRA, Individually, :
jointly and severally : DOCKET NO.
: CAM L 000284-25
AUTOMSMART OF DEPTFORD, individually, : CIVIL ACTION
Jointly and severally :
:
John Doe #1-10, :
Individually, jointly and severally, :
: NOTICE OF MOTION
ABC : FOR ENTRY OF
Corporation #1-100. : DEFAULT JUDGMENT
:
Defendants
Autosmart of Palymra, et al
Route 73 North
Palmyra, NJ 08065
PLEASE TAKE NOTICE that the undersigned counsel for Plaintiff, will apply to the Superior Court of New Jersey, Camden County, as soon as counsel can be heard, for an Order entering default judgment against the defendant, Autosmart of Palymra pursuant to R. 4:43-2(a).
PLEASE TAKE FURTHER NOTICE, that in support of its Motion, plaintiff shall rely upon the Certification of Amount Due and Non-Military Service, and Certification of Joseph Basso, Esq. A proposed form of Order is hereby attached.
PLEASE TAKE FURTHER NOTICE that pursuant to R. 1:6-2 the undersigned waives oral argument.
PLEASE TAKE FURTHER NOTICE that the relief requested may be granted unless opposition papers are timely filed and served upon counsel for plaintiff no later than 8 days before the return date of the motion unless the court relaxes that time.
Attorney for Plaintiff
\s\Joseph Basso, Esq.
Dated: August 6, 2025 JOSEPH BASSO, Esq
December 12 2025
LNYS0421303
$53.82