News & Analysis as of

Affidavits

Marshall Dennehey

Claims for a Hospital’s Negligent Credentialing Must Be Addressed With Sufficient Facts in a Corroborating Expert Affidavit During...

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Angel Tomas v. Dmitry Sandler, DPM, et al., 406 So.3d 1089 (Fla. 3d DCA 2025) - The Third District Court of Appeal affirmed a motion to dismiss related to a negligent credentialing claim on the basis that the presuit...more

Quarles & Brady LLP

Alabama Board of Pharmacy Removes Affidavit Requirement for New Wholesaler Applicants

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At its October 2025 board meeting, the Alabama Board of Pharmacy (the “Board”) voted to remove a requirement that new wholesale distributor applicants sign an affidavit affirming that products distributed in Alabama will only...more

McGlinchey Stafford

Ohio Appeals Court: Denying Arbitration Without Hearing May Be Reversible Error, Even If No Hearing Was Requested

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In a recent ruling from the Eighth District Court of Appeals in Ohio, the court held that where parties present contradicting affidavits of fact, a trial court may commit reversable error by denying a motion to compel...more

White and Williams LLP

U.S. Supreme Court to Decide Whether Medical Malpractice Certificate of Merit Requirements Apply in Federal Courts

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More than half of the states in the country, including Pennsylvania, New Jersey, Delaware and New York, have passed laws requiring a plaintiff in a medical malpractice action to include an affidavit or certificate of merit...more

Jaburg Wilk

Significant Increase in Arizona’s Small Estate Thresholds

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In Arizona a party can collect assets in a small estate without having to open a probate through a form commonly known as a “small estate affidavit.” The purpose of Arizona’s small estate affidavit is to provide a simplified,...more

Marshall Dennehey

Medical Malpractice Suit Dismissed for Inadequate Affidavit of Merit in Wrongful Death Following Kidney Biopsy

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Sovelove v. Shirazi, A-1540-23, Jun. 17, 2025 - The decedent had undergone an elective kidney biopsy and suffered a large retroperitoneal bleed, resulting in her death. The plaintiff, individually and as the estate executor,...more

Kerr Russell

Five Things to Know About the Owner’s Affidavit in Real Estate Transactions

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In real estate transactions, one of the most important documents a seller will execute is the “Owner’s Affidavit” (also sometimes called a “Seller’s Affidavit” or “Affidavit of Title”). Often, purchase agreements require the...more

EDRM - Electronic Discovery Reference Model

[Webinar] Important eDiscovery Case Law Decisions for June 2025 - June 25th, 1:00 pm - 2:00 pm ET

eDiscovery case law disputes are no picnic! In our June 2025 monthly webinar of cases covered by the eDiscovery Today blog we will discuss disputes related to court decided ESI orders, supporting evidence for experts,...more

Dorsey & Whitney LLP

The Supreme Court Update - March 10, 2025

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Today, the Supreme Court of the United States granted certiorari in two cases: Berk v. Choi, No. 24-440: Many states, including Delaware in this case, have “affidavit of merit” statutes that require certain types of...more

Greenbaum, Rowe, Smith & Davis LLP

New Jersey Supreme Court Opinion Refines Affidavit of Merit Requirements for Malpractice Case Against Physician Certified in...

In another in the seemingly endless series of decisions parsing the interpretation of the statutory requirements for an affidavit of merit in medical liability claims, on January 22, 2025 the New Jersey Supreme Court issued...more

Klein Moynihan Turco LLP

Sweepstakes Winner Affidavits

The culmination of every successful sweepstakes promotion involves the picking of a winner, or multiple winners, as applicable. Winner selection also provides the sweepstakes operator with the opportunity to generate positive...more

Epstein Becker & Green

Supreme Court of Ohio Rules on a Peer-Review Privilege Issue in Stull v. Summa

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Background - On December 10, 2024, the Supreme Court of Ohio issued its decision in Stull v. Summa, a medical negligence case in which the defendants argued that Ohio’s statutory peer-review privilege protected from...more

Epstein Becker & Green

Quashing an Out-of-State Subpoena: No Easy Task

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On October 30, 2024, in Alternative Global One, LLC v. Feingold, the New Jersey Appellate Division affirmed a trial court’s orders denying a New Jersey litigant’s motion to quash a subpoena for his deposition in underlying...more

Marshall Dennehey

Appellate Division Maintains Kind-for-Kind, Credential Equivalency Requirement Under Affidavit of Merit Statute

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Wiggins v. Hackensack Meridian Health, 478 N.J. Super. 355 (App. Div. 2024) - The plaintiffs alleged that the defendant, Dr. Goyal, prescribed tramadol to the decedent for pain associated with a medical condition. One month...more

Houston Harbaugh, P.C.

Butler County, Pennsylvania Court Filings to Require Generative AI Affidavit on October 21, 2024

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Starting on Monday, October 21, 2024, the Butler County, Pennsylvania Court of Common Pleas will require an Affidavit about the use of Generative AI to be attached to court filings. This marks a new development in courts’...more

Dickinson Wright

Commercial Lease Modifications: Why Oral Agreements Don’t Hold Up in Court

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Most people likely understand the risks of trying to rely on an oral agreement to vary the terms of a commercial lease. Nonetheless, parties often get into disputes over whether there was an oral agreement that varied the...more

Esquire Deposition Solutions, LLC

Recent Rulings Highlight Importance of Depositions in Litigation

In civil litigation, depositions are a key pretrial discovery tool used to uncover facts, obtain admissions, gather evidence for motions, and assess witnesses. They prevent “trial by ambush” by revealing crucial information...more

Stange Law Firm, PC

What is hearsay in divorce and family law matters?

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Hearsay is an important legal concept that lawyers learn in law school. Under Federal Rule of Evidence 801, hearsay is an out-of-court statement offered for the truth of the matter asserted. Even many lawyers are often...more

Goldberg Segalla

Defendant’s Motion for Summary Judgment Denied Due to Conclusory Affidavits

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Jurisdiction: Supreme Court of New York, New York County - DAP filed a motion for summary judgment by arguing plaintiff cannot sufficiently demonstrate DAP’s exposed him to asbestos. DAP contends that it did not manufacture...more

Marshall Dennehey

Legal Roundup - New Jersey

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An “almost perfect storm of events” warranted additional time to file an Affidavit of Merit. Gonzalez v. Maher Ibrahim, et al., No. A-3719-22, 2024 WL 649332 (N.J. App. Div. Feb. 16, 2024) (approved for publication) - The...more

Marshall Dennehey

An “Almost Perfect Storm of Events” Warranted Additional Time to File an Affidavit of Merit

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Gonzalez v. Maher Ibrahim, et al., No. A-3719-22, 2024 WL 649332 (N.J. App. Div. Feb. 16, 2024) (approved for publication) - The plaintiff and her husband, by way of a per quod claim, initiated a medical malpractice action...more

Epstein Becker & Green

Receive Specialized Care, Provide Specialized Testimony: New Jersey Court Says Medical Malpractice Expert Witness Must Have...

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To diminish the number of frivolous lawsuits that patients file against doctors and hospitals, 28 states require that a plaintiff submit an affidavit or certificate of merit when they file a medical malpractice case....more

Dickinson Wright

Is It Proper to Raise New Arguments or Submit New Evidence in a Motion for Reconsideration?

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A version of this article was previously published in the Michigan Defense Quarterly, Vol. 40, No. 3 (2024). There may be times when a party facing an adverse summary disposition decision (whether it be the grant or denial...more

Marshall Dennehey

An Affidavit of Merit Is Inappropriate if It Fails to Identify Any Individual Person(s) Who Were Negligent.

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Hargett v. Hamilton Park OPCO, LLC, et al., No. A-2036-22, 2023 WL 8533057 (N.J. App. Div. Dec. 11, 2023) (approved for publication) - The trial court dismissed the plaintiff’s complaint with prejudice for failure to provide...more

Farrell Fritz, P.C.

Affirmation in Lieu of an Affidavit, Now “with the Same Force and Effect”

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As of January 1, 2024, the amended CPLR 2106 concerning affirmations provides that - [t]he statement of any person wherever made, subscribed and affirmed by that person to be true under the penalties of perjury, may be...more

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