[brief] This submission also addresses the truly unfortunate cross appeals filed by the Respondents.  A mere 26 months after the accident, the Law Division granted Plaintiffs’ motion to amend the existing complaint to substitute the Respondents in place of John Doe parties that had been timely named in Plaintiffs’ first complaint.  Plaintiff had specified these John Defendants in the initial complaint as those tenants on the day of the accident who may have a contractual or common law obligation to remove snow from the sidewalk.  After filing the initial complaint, Plaintiffs set off on what proved to be a frustrating 10-month journey, thwarted by non-response and a misleading response, in an effort to secure that which they had immediately sought through discovery: a list of tenants as of the date of the accident; and copies of their leases.  The accident occurred at a small strip mall with just a few storefronts.  There is no valid reason why, in order to secure this small amount of information, it had to take Plaintiffs repeated on-going efforts over a ten-month period.  This Court cannot ignore (i) the several months of non-response to interrogatories and document demands; (ii) the failure to comply with a third-party subpoena to a law firm that had represented the tenants in lease negotiations for production of a list of tenants, and copies of their leases; (iii) the necessity for Plaintiffs to have filed a motion to enforce the subpoena; and then finally (iv) the need even for a motion to hold the Respondents’ law firm in contempt for failing to comply with the order enforcing the subpoena.  Even then, the information received from Respondents’ law firm was not entirely accurate.  Although finally providing a list of tenants on the date of the accident, the law firm provided just one lease for a tenant who had been in occupancy on the date of the restaurant – that being the Restaurant.  Moreover, the list of tenants did not include the Nail Salon.  There is no doubt that, from the outset of the case, Plaintiffs set out on what should have been the simple task of obtaining a list of the tenants as of the date of the accident; and their leases in order to assess if such claims could be responsibly asserted against the Respondents.  Respondents have the temerity to argue that Plaintiffs could have “done more” to join them before the second anniversary of the accident.  Respondents effectively contend that Plaintiffs’ counsel should have driven to the mall after being retained after the accident and compiled a list of tenants \textit{then} in possession.  Then, Respondents argue that Plaintiffs -- without knowing if these tenants had actually been in possession on the date of the accident, or whether they had any contractual obligation to maintain the sidewalks on the premises – should have just opened fire on the tenants who just happened to be in possession several months later.  In effect, Respondents effectively contend that Plaintiffs should have ignored Rule 1:4-8.  Did Plaintiffs have any actual basis to allege that these tenants were in possession on the date of the accident?  Not really.  Did Plaintiffs have any basis to allege that their leases imposed a maintenance duty on them?  No.  Once the leases were \textit{finally} produced -- revealing that Respondents had a contractual obligation to remove the snow from the spot where [...] fell – Plaintiffs promptly moved to substitute the Respondents in lieu of John Doe defendants.  That was merely 26 months after the accident.