[brief] (“[...]”), [...], [...], [...], and [...], (herewith in “Defendants), by and through their law firm, [...], their motion to dismiss Plaintiff’s complaint with prejudice by Somerset County Superior Court, pursuant to New Jersey Rule 4:23-5(a)(2).  Plaintiff argues the order dismissing complaint with prejudice, as Defendants’ requests for interrogatories and production of documents were provided by the Plaintiff habitually, discussed multiple times, confirmed acceptance externally/off the record and resubmitted repetitively in nature.  It is further argued, the trial court erred in their review of the Plaintiff’s submitted copies of the Defendants entitled, court ordered discovery requests with due dates and scheduled case management conferences, citing the Plaintiff as delinquent with the need to file a motion to vacate and reinstate pursuant to New Jersey Rule 4:23-5.  Plaintiff satisfied all obligations through counsel and as pro-se (AP1 – AP2)¹.  Defendants on-the-record, opposing responses implied Plaintiff blatantly refused to comply with her discovery obligations.  The Plaintiff never requested to quash any of their subpoenas; Plaintiff found it interesting that the Defendants were fulfilling the discovery obligations for the Plaintiff when they blatantly ¹ [AP #] references brief appendix section followed by page number. requested the information from her, causing confusion, annoyances, erratic disruptions and with extreme inconveniences to her medical providers to the point they no longer felt comfortable with medically treating the Plaintiff.  The Defendants submitted subpoenas to her former employers with the exclusion of one (1) employer, demanding their attendance to discuss their case requirements and discovery demands at an offsite location (AP 3-8)\(^2\).  The first submission of interrogatory answers and production of documents occurred prior to settlement conference on or about June 15, 2021, by Plaintiff’s prior Counsel, [...].  Plaintiff reforwarded the same documents from Plaintiff’s prior Counsel to the Defendants’ Counsel, [...] with additional substantiating documents from July 13, 2022, through October 30, 2022.  Defendants’ Counsel reached out to the Plaintiff on, June 9, 2022, regarding receipt of their Interrogatories and First Set of Production of Documents; on June 21, 2022, via email, Plaintiff responded affirming their discovery demands were already met by the Plaintiff and sent through her former Counsel along with an elaborative response to their Interrogatories request.  On October 26, 2022, Plaintiff received an inquiry from Counsel regarding the location of “page 5” from --- \(^2\)  One (1) employer subpoena packet is attached as an example; there were several sent out with the exclusion of Defendant’s own company and her representatives. the court stamped documents.  Plaintiff informed opposing counsel; the accepted court stamped document from Plaintiff’s prior counsel is a page count error.  Next, Defendants written request to their one hundred question First Set of Production Documents questionnaire and all written discovery correspondence concluded per the trial court’s August court order as requested by Defendants’ motion (AP 66 – AP 67).  **PROCEDURAL HISTORY AND STATEMENT OF FACTS**