We are pleased to announce a successful outcome on behalf of our client in a complex post-judgment enforcement proceeding in the Superior Court of New Jersey, Somerset County.
Our client obtained a final judgment exceeding $4.6 million USD against a defendant arising out of a contract dispute originally litigated in Hong Kong. With that judgment remaining wholly unsatisfied, Kublanovsky Law pursued aggressive post-judgment enforcement efforts, including serving a discovery subpoena on a third-party witness believed to possess information concerning the location of the judgment debtor’s assets. The witness, whose parents allegedly served as past controllers and trustees of the judgment debtor, refused to comply with the subpoena, demanding that our client first produce all documents intended to be used at the deposition before she would appear.
We moved to compel compliance with the subpoena, arguing that no such pre-deposition disclosure obligation exists under New Jersey’s discovery rules and that requiring advance production of our litigation materials would improperly compromise privileged attorney work product. The witness filed a cross-motion seeking to compel production of those documents before proceeding with the deposition.
The court granted our motion to compel in full and denied the witness’s cross-motion entirely. The court found that our client was entitled to fully explore the witness’s knowledge of the judgment debtor’s assets and that the witness had failed to demonstrate the good cause necessary to obtain any form of protective relief.
This result reflects our firm’s tenacity in pursuing all available avenues to enforce our clients’ judgments and protect their rights in complex, multi-jurisdictional matters.
For more information about our commercial litigation practice, please contact our office.
