Rainey v. Republic Services of NJ. In her lawsuit, plaintiff sought damages for personal injuries sustained during an alleged motor vehicle accident when plaintiff’s vehicle collided with a vehicle controlled by co-defendant Henry E. Graves, Jr. and owned by co-defendant Wilkie Trucking, Inc. Republic Services of New Jersey, LLC. was not a named defendant in plaintiff’s Original Complaint. Plaintiff sought to amend her complaint to include Republic Services of NJ in an amended complaint after the statute of limitations had expired. Chris Mauro and Katelyn Marquez argued that plaintiff’s complaint should be dismissed as time barred under N.J.S.A. 2A:14-2(a). Judge Adams agreed with our arguments and found that plaintiff did not show due diligence in learning of Republic’s identity within the Statute of Limitations and that there was undue prejudice to Republic Services to be brought into this lawsuit after there had been 1076 days of discovery.