Darren J. Del Sardo
How Judge Sardo rules, drawn from 6 signed orders. Every observation links to the order it came from.
About Judge Sardo
Darren J. Del Sardo is a judge of the Superior Court of New Jersey in the Passaic Vicinage and serves as its civil presiding judge. He joined the court in December 2020 and became civil presiding judge in September 2023. He earned degrees from Seton Hall University and Touro Law Center.
Judge Sardo's practices and standing orders
The court's website lists no individual practices or standing orders of Judge Sardo's own (checked October 11, 2026), so the court's local rules and general orders are the place to look (court page ↗).
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 11, 2026).
How Judge Sardo decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Wiggins Plastics v. County of Passaic, DeL Sardo denied a protective order seeking to avoid identifying documents that supported the plaintiffs’ damages calculation. He found the attorney’s certification did not establish undue burden because no person with knowledge of the plaintiffs’ document production had supplied one.
“There is no certification from Polevoy or anyone else associated with plaintiffs claiming that production of documents, or identifying the previously served documents by Bates Stamp numbers, would be unduly burdensome or expensive.”
In Paterson Board of Education v. DiMartino, DeL Sardo rejected a group pleading objection to fraud and related claims at the dismissal stage. He found the alleged scheme plausibly implicated each defendant, while dismissing the Consumer Fraud Act counts on a separate ground.
“The court rejects the defendants' arguments that the allegations are conclusory or that group pleading is impermissible, as the allegations reasonably implicate each defendant.”
On a motion to dismiss for conversion or replevin of fungible but identifiably branded property, circumstantial evidence of unauthorized possession and resale (site inspections, invoices, the defendant's own admissions) is enough to proceed, without the plaintiff pinpointing which specific unit was converted.
“This alleged scheme provides a basis for a cause of action for conversion, the wrongful exercise of dominion and control over property owned by another inconsistent with the owner's rights.”
In Dry Clean Express II, DeL Sardo left the disputed existence of a contract and the alternative unjust enrichment claim for a jury after finding the evidence could support either conclusion.
“a jury could conclude that no contract existed between the parties, finding a lack of mutual agreement, consideration, or certainty. Alternatively, the jury may determine that the Defendant was unjustly enriched.”
Procedural preferences
In Wiggins Plastics, DeL Sardo rejected the claimed burden of identifying previously produced documents because the plaintiffs supplied only their counsel's certification, and counsel lacked personal knowledge of the burden or expense.
“Plaintiffs' support for their motion is a certification from plaintiffs' counsel... Plaintiffs' Counsel does not have personal knowledge regarding the burden or expense of document production, as required by R. 1:6-6.”
In Paterson Board of Education v. DiMartino, DeL Sardo partially granted the defendants' separate motions to dismiss the complaint.
“the Motions of all filing Defendants are PARTIALLY GRANTED.”
Cautions
In Paterson Board of Education v. DiMartino, DeL Sardo held that the complex, negotiated agreements between sophisticated businesses were not consumer transactions under the Consumer Fraud Act.
“the court concludes that these were complex, negotiated, business-to-business agreements involving sophisticated entities, not consumer transactions subject to the CFA.”
In Dry Clean Express II, DeL Sardo held that a fraud claim could not stand where it duplicated the contract claim arising from a purely contractual relationship.
“A claim for fraud cannot stand when it merely replicates the basis for a breach-of-contract claim, particularly when the relationship between the parties is purely contractual.”
In the Wiggins Plastics flood-damage dispute, he rejected a first-party indemnity claim because none of three agreements clearly stated that the county would pay the property owners’ own losses.
“none of the three provisions: neither Agreement Provision 5.1.C, Agreement Provision 11, nor Deed Paragraph 4 contain the express, deliberate, or unequivocal language required to provide for first party indemnification.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“ORDERED that Plaintiffs' appeal of the Special Adjudicator's Report dated October 27, 2025 is hereby DENIED”
“the Motions of all filing Defendants are PARTIALLY GRANTED... the motions to dismiss Counts 10 and 11 are GRANTED, and these counts are DISMISSED, without prejudice.”
“the Plaintiff has demonstrated that a genuine issue of material fact remains for the jury to resolve regarding the Defendant's alleged breach of contract, unjust enrichment, and breach of the duty of good faith and fair dealing. All other claims brought by the Plaintiff are unsupported and cannot be sustained and are hereby dismissed.”
“Accordingly, based on the aforementioned reasons, the Defendant's Motion is hereby DENIED.”
“Accordingly, the County Defendants’ application to bar Plaintiffs’ surveys prepared by Casey & Keller, Inc., together with the request to bar all opinions contained in the Peckham and McHugh reports that reference those surveys, is hereby DENIED with prejudice.”
“ORDERED that summary judgment be and hereby is granted in favor of Defendants, County of Passaic and Passaic County Board of Commissioners, dismissing Plaintiffs’ contractual indemnity claims as set forth in the First Count of Plaintiffs’ Second Amended Complaint”
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