MOTION TO DISMISS – ESSEX COUNTY
6/27/2026 – Waldron-Reeves Michelle v. 321 Park Avenue, LLC, 195 Prospect Street Holdings Company EO LLC and One Wall Management LLC
Plaintiff Michelle Waldron-Reeves sought recovery for personal injuries allegedly sustained in an incident that occurred on August 15, 2020, while traversing a staircase at 195 Prospect Street in Essex County, New Jersey. Before the parties engaged in extensive discovery, Sofia O’Shea established that plaintiff’s claims against defendants 195 Prospect Street Holdings Company, E.O., LLC, and One Wall Management LLC were time-barred because plaintiff failed to timely amend the summons and complaint to name the proper defendants before the expiration of the applicable statute of limitations. Despite plaintiff’s efforts to demonstrate reasonable diligence in identifying and locating the proper defendants, Sofia O’Shea successfully showed that plaintiff had not exercised the requisite diligence and that defendants would be substantially prejudiced if forced to defend a years-old action. Judge Jennifer Critchley agreed that permitting the action to proceed under these circumstances would be unfair and granted our motion to dismiss all claims against 195 Prospect Street Holdings Company, E.O., LLC, and One Wall Management LLC as barred by the statute of limitations.

