COHEN, PLACITELLA & ROTH, P.C. 

Christopher M. Placitella, Esq. (027781981) 

Michael Coren, Esq. (024871979) 

Jared M. Placitella, Esq. (068272013) 

Eric S. Pasternack, Esq. (015132011) 

127 Maple Avenue 

Red Bank, NJ 07701 

(732) 747-9003

FOX ROTHSCHILD LLP 

Jeffrey M. Pollock, Esq. (015751987) 

997 Lenox Drive, Building 3 

Princeton Pike Corporate Ctr. Lawrenceville, NJ 08648 

(609) 896-3600

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

KIMBERLEE WILLIAMS, et al.

 

 Plaintiffs,

 vs.

BASF CATALYSTS LLC, et al.

 

 Defendants.

No. 2:11-cv-01754 (JLL) (JAD)

CIVIL ACTION

CERTIFICATION OF 

COUNSEL

CHRISTOPHER M. PLACITELLA, of full age, hereby certifies as follows:

1. I am an attorney at law in the State of New Jersey and a shareholder 

with the law firm of Cohen, Placitella and Roth, P.C.

Case 2:11-cv-01754-BRM-AME Document 586-2 Filed 06/20/18 Page 1 of 4 PageID: 41021
2. I am familiar with the facts and circumstances of the within action.

3. Attached as Exhibit 1 is a true and correct copy of the June 7, 2018 

Interim Order from Special Master Re ECF No. 531. 

4. Attached as Exhibit 2 is a true and correct copy of the June 18, 2018 

Order from Special Master Re ECF No. 581.

5. Attached as Exhibit 3 is a true and correct copy of the May 12, 2018 

Order from Special Master Re ECF No. 493. 

6. Attached as Exhibit 4 is a true and correct copy of the June 12, 2018 

Order from The Honorable Jose L. Linares Re ECF No. 571. 

7. Attached as Exhibit 5 is a true and correct copy of ECF filing 531 

BASF letter to Special Master dated May 21, 2018.

8. Attached as Exhibit 6 is a true and correct copy of ECF filing 540 

Plaintiffs’ letter to Special Master dated June 1, 2018.

9. Attached as Exhibit 7 is a true and correct copy of ECF filing 545, a

letter from counsel for Thomas Bevan, Esquire dated June 1, 2018.

10. Attached as Exhibit 8 is a true and correct copy of ECF filing 552, 

BASF letter to Special Master dated June 6, 2018.

11. Attached as Exhibit 9 is a true and correct copy of ECF filing 493-2, 

Subpoena to Produce Documents directed to Bevan & Associates dated November 

21, 2016.

Case 2:11-cv-01754-BRM-AME Document 586-2 Filed 06/20/18 Page 2 of 4 PageID: 41022
12. Attached as Exhibit 10 is a true and correct copy of the October 26, 

2017 Transcript of Proceedings before Special Master Roberto A. Rivera-Soto.

13. Attached as Exhibit 11 is a true and correct copy of Plaintiffs’ 

Objections to Defendant BASF Catalysts LLC’s Subpoena Served Upon Thomas 

Bevan and Bevan Associates LPA, Inc.

14. Attached as Exhibit 12 is a true and correct copy of BASF letter to 

The Honorable Joseph A. Dickson dated February 16, 2017 ECF 242.

15. Attached as Exhibit 13 is a true and correct copy of BASF letter to 

Special Master dated April 27, 2018 ECF 493.

16. Attached as Exhibit 14 is a true and correct copy of BASF letter to 

Christopher M. Placitella, Esquire dated June 13, 2018.

17. Attached as Exhibit 15 is a true and correct copy of Plaintiffs’ letter to 

The Honorable Jose L. Linares dated June 14, 2018 ECF 577.

18. Attached as Exhibit 16 is a true and correct copy of Special Master 

Roberto A. Rivera-Soto letter to Christopher M. Placitella dated June 15, 2018.

19. Attached as Exhibit 17 is a true and correct copy of Plaintiffs’ letter to 

Special Master dated June 18, 2018 ECF 581.

20. Attached as Exhibit 18 is a true and correct copy of Order from 

Special Master ECF 581 dated June 18, 2018.

Case 2:11-cv-01754-BRM-AME Document 586-2 Filed 06/20/18 Page 3 of 4 PageID: 41023
21. Attached as Exhibit 19 is a true and correct copy of Thomas Bevan, 

Esquire’s deposition transcript dated May 15, 2018.

22. Attached as Exhibit 20 is a true and correct copy of a letter from 

Christopher M. Placitella to Plaintiff Kimberlee Williams dated March 15, 2011.

23. Attached as Exhibit 21 is a true and correct copy of Plaintiff Donnette 

Wengerd’s deposition transcript dated April 6, 2017.

24. Attached as Exhibit 22 is a true and correct copy of Plaintiff Donnette 

Wengerd’s deposition transcript dated March 12, 2018.

25. Attached as Exhibit 23 is a true and correct copy of the June 18, 2018 

email from the Special Discovery Master.

I certify that the foregoing statements made by me are true. I am aware that 

if any of the foregoing statements by me are willfully false, I am subject to 

punishment.

COHEN, PLACITELLA & ROTH, P.C.

/s/ Christopher M. Placitella

CHRISTOPHER M. PLACITELLA

Dated: June 20, 2018

Case 2:11-cv-01754-BRM-AME Document 586-2 Filed 06/20/18 Page 4 of 4 PageID: 41024