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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

KIMBERLEE WILLIAMS, et al.,

 Plaintiffs,

 vs.

BASF CATALYSTS LLC, et al.,

 

 Defendants.

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY

DOCKET NO. 11-1754

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.

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 CM/ECF # 534.

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4. Attached as Exhibit 2 is a true and correct copy of Notice of Appeal of 

the Cost-Shifting Order (CM/ECF #534).

5. Attached as Exhibit 3 is a true and correct copy of Superseding Order 

from Special Master ECF Nos. 516 and 534 (CM/ECF # 565).

6. Attached as Exhibit 4 is a true and correct copy of Plaintiffs’ Third Set 

of Interrogatories and Fifth Set of Document Requests Addressed to Defendant 

BASF Catalysts, LLC.

7. Attached as Exhibit 5 is a true and correct copy of BASF Responses 

and Objections to Plaintiffs’ Third Set of Interrogatories and 5th Set of Request for 

Production of Documents.

8. Attached as Exhibit 6 is a true and correct copy of Plaintiffs Motion to 

Compel answers to interrogatories and request for production of documents.

9. Attached as Exhibit 7 is a true and correct copy of BASF’s opposition 

to Plaintiffs’ Motion to Compel. 

10. Attached as Exhibit 8 is a true and correct copy of Declaration of Kevin 

Wood (CM/ECF # 529-14).

11. Attached as Exhibit 9 is a true and correct copy of CM/ECF # 533.

12. Attached as Exhibit 10 is a true and correct copy of Order from Special 

Master CM/ECF # 362.

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13. Attached as Exhibit 11 is a true and correct copy of the transcript of the 

October 26, 2017 hearing.

14. Attached as Exhibit 12 is a true and correct copy of the transcript of the 

May 14, 2018 deposition of Arthur Dornbusch, Esq.

15. Attached as Exhibit 13 is a true and correct copy of the transcript of the 

April 24, 2018 deposition of Michael Hassett.

16. Attached as Exhibit 14 is a true and correct copy of the transcript of the 

May 6, 2018 deposition of Daniel Steinmetz.

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.

Attorneys for Plaintiffs

By: /s/ Christopher M. Placitella

Christopher M. Placitella, Esq.

127 Maple Avenue

Red Bank, NJ 07701

732-747-9003

Dated: June 25, 2018

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