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  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
  • Choates Sr Darrell Vs Deborah HospitalDefamation document preview
						
                                

Preview

BUR-L-000679-23 09/28/2023 8:57:21 PM Pg 1 of 2 Trans ID: LCV20232973841 DeNITTIS OSEFCHEN PRINCE, P.C. Stephen P. DeNittis, Esq. (031981997) Joseph A. D’Aversa, Esq. (046641995) 5 Greentree Centre 525 Rt. 73 North, Suite 410 Marlton, NJ 08053 Phone (856) 797-9951 Fax (856) 797-9978 Email jdaversa@denittislaw.com Attorney for Defendant/Counterclaimant David Dovell and Intervenor/Counterclaimant Marissa Dovell DARRELL CHOATES, SR., : SUPERIOR COURT OF NEW JERSEY : LAW DIVISION Plaintiff, : BURLINGTON COUNTY : vs. : DOCKET NO.: BUR-L-000679-23 : DEBORAH HOSPITAL and DAVID A. : Civil Action DOVELL, : : Defendant. : CERTIFICATION OF : STEPHEN P. DeNITTIS, ESQUIRE : : I, Stephen P. DeNittis of full age, certify as follows: 1. I am an Attorney at Law in the State of New Jersey and managing partner for DeNittis Osefchen Prince, P.C., attorneys for Defendant/Counterclaimant David Dovell (“David Dovell”) regarding his claim against Plaintiff in the above-captioned matter and for Intervenor/Counterclaimant Marissa Dovell (“Marissa Dovell”) who has filed a motion to intervene in the above-captioned matter which is currently pending before this Court, and am fully aware of the facts of this case pertaining to the allegations contained in Plaintiff’s motion to disqualify my firm, DeNittis Osefchen Prince, P.C., and me from this matter. 2. I make this Certification in support of the opposition to Plaintiff’s aforementioned motion. 1 BUR-L-000679-23 09/28/2023 8:57:21 PM Pg 2 of 2 Trans ID: LCV20232973841 3. I have had no involvement in this case, whatsoever, other than my review of Plaintiff’s motion to disqualify my firm and me, receiving email notifications of electronic filings in this matter, but not reviewing such filings, and some very brief conversations with the attorney from my firm handling this matter, Joseph A. D’Aversa, Esquire. I have never met David Dovell or Marissa Dovell or had any communication with them. 4. I have no knowledge of a personal relationship and/or professional relationship between Lora M. Foley, Esquire and the Honorable Aimee R. Belgard, P.J. Cv. as alleged by Plaintiff in his motion. 5. I have not been in direct communications with Andrew S. Winegar, Esquire of Parker McKay regarding any aspect of this case as alleged by Plaintiff in his motion. 6. Neither I nor my firm have filed a motion for dismissal in this matter as alleged by Plaintiff in his motion. 7. The professional relationship between Judge Belgard and me predated her appointment to the bench. 8. Judge Belgard and I have never had a personal relationship. 7. Based on the foregoing, I respectfully request that Plaintiff’s motion to disqualify DeNittis Osefchen Prince, P.C. and me from the above-captioned matter be dismissed. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. DATED: September 28, 2023 By: Stephen P. DeNittis, Esq. 2 BUR-L-000679-23 09/28/2023 8:57:21 PM Pg 1 of 1 Trans ID: LCV20232973841 DeNITTIS OSEFCHEN PRINCE, P.C. Stephen P. DeNittis, Esq. (031981997) Joseph A. D’Aversa, Esq. (046641995) 5 Greentree Centre 525 Rt. 73 North, Suite 410 Marlton, NJ 08053 Phone (856) 797-9951 Fax (856) 797-9978 Email jdaversa@denittislaw.com Attorney for Defendant/Counterclaimant David Dovell and Intervenor/Counterclaimant Marissa Dovell DARRELL CHOATES, SR., : SUPERIOR COURT OF NEW JERSEY : LAW DIVISION Plaintiff, : BURLINGTON COUNTY : vs. : DOCKET NO.: BUR-L-000679-23 : DEBORAH HOSPITAL and DAVID A. : Civil Action DOVELL, : : Defendant. : PROOF OF SERVICE : : I, Joseph A. D’Aversa, Esquire, of full age, hereby certify as follows: On September 28, 2023, the within certification was filed on eCourts and provided to Darrell K. Choates, Sr. via email and to Lora M. Foley, Esquire and R, James Kravitz, Esquire via eCourts and email. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. DeNITTIS OSEFCHEN PRINCE, P.C. Attorneys for Defendant/Counterclaimant and Intervenor/Counterclaimant BY: Dated: September 28, 2023 JOSEPH A. D’AVERSA 1