Document for Choates Sr Darrell Vs Deborah Hospital

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                                BUR-L-000679-23 08/04/2023 Pg 1 of 2 Trans ID: LCV20232273819




Darrell Choates
122 Danton Lane
Mullica Hill NJ 08062
August 4, 2023
Honorable Aimee R. Belgard, P.J.Cv.
Burlington County Superior Court
49 Rancocas Road
Mt. Holly, New Jersey 08060

Re:    Choates vs. Deborah Heart & Lung Center, et al. Docket No. BUR-L-0679-23.
Dear Judge Belgard,

I hope this letter finds you in good health. My name is Darrell Choates, and I am the plaintiff in
the above-mentioned case. I am writing to respectfully request your reconsideration on certain
matters pertaining to the affidavit of merit and my fair trial rights.

Firstly, I kindly request the Court's attention to the fact that opposing counsel, who is an ESQ,
lacks the necessary qualifications and expertise to argue the merit of the affidavit provided by my
expert, Dr Ramesh Parchuri. As you are aware, the affidavit of merit is crucial in substantiating
my claim of medical malpractice against the defendants. However, I have learned that the
opposing counsel has made assertions regarding the merit of the affidavit, despite not being a
licensed healthcare professional. I firmly believe that only qualified healthcare professionals
possess the requisite knowledge and expertise to address the medical aspects of my claim, and I
request the Court's acknowledgment and restriction on opposing counsel's argument based on
this ground.

Furthermore, I assert that the basis of my claim goes beyond medical issues and also involves
matters of patient care, emotional distress, and violation of patient rights. My claim seeks relief
for the negligent actions and emotional harm caused by the defendant's staff, particularly David
A. Dovell, a registered nurse, whose actions are central to this case.

Secondly, I strongly advocate for my fair right to trial and dispute any attempts to compromise
this right. I firmly believe that my claim should be presented in court at trial, where my expert
witnesses, including health professionals and certified experts, can testify and dispute the
defendant's claim. I seek a fair trial, where both parties have an equal opportunity to present
             BUR-L-000679-23 08/04/2023 Pg 2 of 2 Trans ID: LCV20232273819




evidence, cross-examine witnesses, and present expert opinions to seek the truth and pursue
justice. On the record, is the second affidavit of Dr Eric Musyoka and an expert opinion from a
practicing nurse who have rendered their certified opinions under oath.

I believe that any argument or claim made in the affidavit should be subject to trial scrutiny,
allowing my expert witnesses to provide counter-evidence and challenge the veracity of the
defendant's claims. I sincerely hope that the trial will serve as the appropriate forum for such
disputes, and I request your assurance that my right to a fair trial will be upheld.

I respectfully request the Court's consideration of these matters and the granting of the relief
sought to ensure a fair and just resolution of this case.

Thank you for your attention to this important matter. I eagerly await the Court's ruling on my
reconsideration request.


Sincerely,




Darrell Choates