New Jersey Department of Children & Families v. E.L., ___ N.J. Super. ___ (App. Div. 2018).  Courts often give public entity parties more leeway in complying with rules, court orders, and the like than private parties are given.  Sometimes Court Rules themselves give preference to public agencies, as is so, for example, of Rule 2:9-6(b), which exempts the State, its political subdivisions, and “any of their respective officers or agencies” fro

State of New Jersey in the Interest of N.P., ___ N.J. Super. ___ (App. Div. 2018).  This decision by Judge Messano addresses four appeals involving seven different juveniles. The broad issue presented was “whether a juvenile complaint charging a crime or repetitive disorderly persons offense may be diverted without the prosecutor’s consent.”  Judge Messano carefully analyzed the applicable statutory and court rule sources of relevant law, and concl

Baez v. Paulo, ___ N.J. Super. ___ (App. Div. 2018).  This was a medical malpractice/wrongful death case.  The Law Division had precluded plaintiff from adding three doctors as defendants after the statute of limitations had expired, ruling that plaintiff had not exercised sufficient diligence to identify those defendants, who had been named as fictitious defendants under Rule 4:26-4, in timely fashion.  Despite having found that the statute of limitations had run out as to the three doctors, t