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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.
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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.
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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
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