Objection to motion submitted by Darrell Choates. JEDS EF-2274952

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                                 BUR-L-000679-23 2023-10-23 09:42:58.742 Pg 1 of 12 Trans ID: LCV20233182853




                             IN THE SUPERIOR COURT OF NEW JERSEY

                                     BURLINGTON COUNTY

DARRELL CHOATES,                                       DOCKET NO. BUR-L-0679-23
                Plaintiff,

vs.                                                    PLAINTIFFS' OPPOSITION TO

DEBORAH HOSPITAL AND DAVID A.                          DEFENDANT DAVID A DOVELL’S
DOVEL
                                                       MOTION TO DISMISS
         Defendants




  I.     RELIMINARY STATEMENT

         The Defendant's motion seeks dismissal of the Complaint on the grounds of failure to

state a claim. However, the undersigned contends that the Complaint adequately pleads the

essential elements of each cause of action, and the Defendant's motion should be denied.

Furthermore, the Plaintiff has sought leave for an amended complaint to cure any perceived

deficiencies, as…