SELECTIVE TRANSPORTATION CORPORATION VS. GUSSCO MANUFACTURING, LLC DIRECT COAST TO COAST, LLC VS. GUSSCO MANUFACTURING, LLC (L-8013-12, L-8018-12 AND J-198852-13, MIDDLESEX COUNTY AND STATEWIDE), A-4233-16T1

Selective Transportation Corp. and Direct Coast to Coast, LLC (collectively, Selective) obtained a consent judgment against Selco Industries for unpaid freight charges, stayed pending Selco's compliance with a payment plan.
Selco defaulted on the consent order and later filed for Chapter 11; its bankruptcy was dismissed in 2016, after which Selective resumed execution efforts.
Selective served information subpoenas on non‑party S.P. Richards Co. (SPR) seeking records showing amounts SPR owed Selco; SPR initially refused and later claimed it owed a smaller sum than Selective alleged.
After a denied motion in aid of execution (for procedural noncompliance), Selective served a broad subpoena duces tecum on SPR for five years of records concerning Selco.
The trial court granted SPR’s motion to quash that subpoena but issued no statement of reasons with the order.
Selective appealed, arguing the order was defective because the court failed to provide the required statement of reasons under Rule 1:7-4(a); the Appellate Division remanded for that reason without reaching the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by entering an order quashing the subpoena duces tecum without a statement of reasons	The court must attach written reasons to an order quashing a subpoena per Rule 1:7-4(a); absence of reasons prevents meaningful review	Court did not provide reasons; SPR defended quash but did not dispute the Rule 1:7-4(a) requirement	Reversed and remanded: trial court’s order lacked the required statement of reasons, so appellate court could not review merits

Curtis v. Finneran, 83 N.J. 563 (N.J. 1980) (absence of adequate judicial rationale is a disservice to litigants and appellate review)
Kenwood Assocs. v. Bd. of Adjustment, Englewood, 141 N.J. Super. 1 (App. Div. 1976) (importance of providing reasons for judicial decisions)
Gnall v. Gnall, 222 N.J. 414 (N.J. 2015) (reiterating need for trial court to state reasons)
State v. Lawrence, 445 N.J. Super. 270 (App. Div. 2016) (same)
Raspantini v. Arocho, 364 N.J. Super. 528 (App. Div. 2003) (same)
In re Farnkopf, 363 N.J. Super. 382 (App. Div. 2003) (same)
T.M. v. J.C., 348 N.J. Super. 101 (App. Div. 2002) (same)
Grubb v. Borough of Hightstown, 353 N.J. Super. 333 (App. Div. 2002) (issues not briefed on appeal are deemed abandoned)