The following is current NJ Court Rules on Answers in a Civil Complaint in the     Superior Court Law Division.

RULE 4:5. GENERAL RULES OF PLEADING Court 4:5-1. General Requirements for Pleadings

(a) Pleadings Allowed. There shall be a Complaint and an Answer; an answer to a     counterclaim denominated as such; an answer to a cross-claim, if the answer contains a     cross-claim; a third-party complaint pursuant to R. 4:8; a third-party answer, if a     third-party complaint is served; and a reply, if an affirmative defense is set forth in an     answer and the pleader wishes to allege any matter constituting an avoidance of the     defense. No other pleading is allowed.

(b) Requirements for First Pleadings. (1) Case Information Statement. Except in civil     commitment actions brought pursuant to R. 4:74-7 and in actions in probate, foreclosure     and all other general equity actions, a Case Information Statement in the form prescribed     by Appendix XII to these rules shall be annexed as a cover sheet to each party's first     pleading.

(2) Notice of Other Actions and Potentially Liable Persons. Each party shall include     with the first pleading a certification as to whether the matter in controversy is the     subject of any other action pending in any court or of a pending arbitration proceeding,     or whether any other action or arbitration proceeding is contemplated; and, if so, the     certification shall identify such actions and all parties thereto. Further, each party     shall disclose in the certification the names of any non-party who should be joined in the     action pursuant to R. 4:28 or who is subject to joinder pursuant to R. 4:29-1(b) because     of potential liability to any party on the basis of the same transactional facts. Each     party shall have a continuing obligation during the course of the litigation to file and     serve on all other parties and with the court an amended certification if there is a     change in the facts stated in the original certification. The court may require notice of     the action to be given to any non-party whose name is disclosed in accordance with this     rule or may compel joinder pursuant to R. 4:29-1(b). If a party fails to comply with its     obligations under this rule, the court may impose an appropriate sanction including     dismissal of a successive action against a party whose existence was not disclosed or the     imposition on the noncomplying party of litigation expenses that could have been avoided     by compliance with this rule. A successive action shall not, however, be dismissed for     failure of compliance with this rule unless the failure of compliance was inexcusable and     the right of the undisclosed party to defend the successive action has been substantially     prejudiced by not having been identified in the prior action.

4:5-2. Claim for Relief

  Except as may be more specifically provided by these rules in respect of     specific actions, a pleading which sets forth a claim for relief, whether an original     claim, counter-claim, cross-claim or third-party claim, shall contain a statement of the     facts on which the claim is based, showing that the pleader is entitled to relief, and a     demand for judgment for the relief to which the pleader claims entitlement. Relief in the     alternative or of several different types may be demanded. If unliquidated money damages     are claimed in any court, other than the Special Civil Part, the pleading shall demand     damages generally without specifying the amount. If a pleading filed in the Special Civil     Part states a demand in excess of the amount cognizable in that court, said pleading shall     be filed by the clerk for the full cognizable amount and any amount in excess thereof     shall be deemed waived unless the action is transferred pursuant to R. 6:4-1. The clerk of     the Special Civil Part shall, in any pleading filed that does not set forth a cognizable     amount, consider the demand to be for the maximum amount and the maximum filing fee shall     be charged. Upon service of a written request by another party, the party filing the     pleading shall within 5 days after service thereof furnish the requesting party with a     written statement of the amount of damages claimed, which statement shall not be filed     except on court order.

4:5-3. Answer; Defenses; Form of Denials

  An Answer shall state in short and plain terms the pleader's defenses to each     claim asserted and shall admit or deny the allegations upon which the adversary relies. A     pleader who is without knowledge or information sufficient to form a belief as to the     truth of an allegation shall so state and, except as otherwise provided by R. 4:64-1(b)     (foreclosure actions), this shall have the effect of a denial. Denials shall fairly meet     the substance of the allegations denied. A pleader who intends in good faith to deny only     a part or a qualification of an allegation shall specify so much of it as is true and     material and deny only the remainder. The pleader may not generally deny all the     allegations but shall make the denials as specific denials of designated allegations or     paragraphs.

4:5-4. Affirmative Defenses; Misdesignation of Defense and Counterclaim

  A responsive pleading shall set forth specifically and separately a statement of     facts constituting an avoidance or affirmative defense such as accord and satisfaction,     arbitration and award, contributory negligence, discharge in bankruptcy, duress, estoppel,     failure of consideration, fraud, illegality, injury by fellow servant, laches, license,     payment, release, res judicata, statute of frauds, statute of limitations, and waiver. If     a party has mistakenly designated a defense as a counterclaim or a counterclaim as a     defense, the court, on terms if the interest of justice requires, shall treat the pleading     as if there had been a proper designation.

4:5-5. Effect of Failure to Deny

  Allegations in a pleading which sets forth a claim for relief, other than those     as to the amount of damages, are admitted if not denied in the answer thereto. In every     action brought upon a negotiable instrument, the authenticity of any signature or     endorsement thereon shall be taken to be admitted unless the same is put in issue by the     pleadings. Allegations in any answer setting forth an affirmative defense shall be taken     as denied if not avoided in a reply; issue shall be deemed to have been joined upon     allegations in an answer setting forth other matters. Allegations in a reply shall be     taken as denied or avoided, and any defense thereto in law or fact may be asserted at     trial.

4:5-6. Consistency

  A party may set forth 2 or more statements of a claim or defense alternatively     or hypothetically, either in one count or defense or in separate counts or defenses. When     2 or more statements are made in the alternative and one of them, if made independently,     would be sufficient, the pleading is not made insufficient by the insufficiency of one or     more of the alternative statements. As many separate claims or defenses as the party has     may be stated regardless of their consistency and whether based on legal or on equitable     grounds or on both. All statements shall be made subject to the obligations set forth in     R. 1:4-8.

4:5-7. Pleadings to Be Concise and Direct; Construction

  Each allegation of a pleading shall be simple, concise and direct, and no     technical forms of pleading are required. All pleadings shall be liberally construed in     the interest of justice.

4:5-8. Pleading Special Matters (a) Fraud; Mistake; Condition of Mind. In all     allegations of misrepresentation, fraud, mistake, breach of trust, willful default or     undue influence, particulars of the wrong, with dates and items if necessary, shall be     stated insofar as practicable. Malice, intent, knowledge, and other condition of mind of a     person may be alleged generally. (b) Conditions Precedent. In pleading the performance or     occurrence of conditions precedent, it is sufficient to allege generally that all such     conditions have been performed or have occurred. A denial of performance or occurrence     shall be made specifically and with particularity, but when so made the party pleading the     performance or occurrence has the burden of establishing it. (c) Pleading According to     Legal Effect. Acts and contracts may be stated according to their legal effect, but in so     doing the pleading should be such as fairly to apprise the adverse party of the state of     facts which it is intended to prove; thus, an act or promise of a principal other than a     corporation, if in fact proceeding from an agent known to the pleader, should be so     stated. In pleading an official document or official act it is sufficient to allege that     the document was issued or the act done in compliance with law. (d) Judgment. A judgment     or decision of a domestic or foreign court, judicial or quasi-judicial tribunal, or     administrative agency or officer, may be alleged without stating matter showing     jurisdiction to render it. (e) Time and Place. For the purpose of testing the sufficiency     of a pleading, allegations of time and place are material and shall be considered like all     other allegations of material matter. (f) Special Damage. Items of special damage claimed     shall be specially stated, except that if a general demand for unliquidated damages is     made pursuant to R. 4:5-2, the facts giving rise to any included claim for special damages     shall be specially stated in lieu of the monetary claim therefor.

RULE 4:6. DEFENSES AND OBJECTIONS: WHEN AND HOW PRESENTED; BY PLEADING OR MOTION;     MOTION FOR JUDGMENT ON PLEADINGS 4:6-1. When Presented    (a) Time;     Presentation. Except as otherwise provided by R. 4:7-5(c) (cross claims), 4:8-1(b)     (third-party joinder), 4:9-1 (answer to amended complaint), and 4:64-1(g) (governmental     answer in foreclosure actions), the defendant shall serve an answer, including therein any     counterclaim, within 35 days after service of the summons and complaint on that defendant.     If service is made as provided by court order, pursuant to R. 4:4-4(b)(3), the time for     service of the answer may be specified therein. Service of the answer shall be complete as     provided by R. 1:5-4. A party served with a pleading stating a counterclaim or cross claim     against that party shall serve an answer thereto within 35 days after the service upon     that party. A reply to an answer, where permitted, shall be served within 20 days after     service of the answer. (b) Time; Effect of Certain Motions. Unless the court fixes a     different time period, the time periods prescribed in paragraph (a) of this rule are     altered by the filing and service of a motion under R. 4:6 or for summary judgment under     R. 4:46 or R. 4:69-2 as follows: (1) if the motion is denied in whole or part or its     disposition postponed until trial, the responsive pleading shall be served within 10 days     after notice of the court's action; (2) if a motion for a more definite statement is     granted, the responsive pleadings shall be served within 10 days after the service of such     statement. If notice is given a nonresident party demanding security for costs and the     nonresident gives notice of the filing of the bond or the making of the deposit, the party     making the demand shall then have the same time to plead as may have remained at the time     of the service of the notice demanding the security. (c) Time; Extension by Consent. The     time for service of a responsive pleading may be enlarged for a period not exceeding 60     days by the written consent of the parties, which shall be filed with the responsive     pleading within said 60-day period. Further enlargements shall be allowed only on notice     by court order, on good cause shown therefor. (d) Certificate of Service. The party filing     the responsive pleading or the party's attorney shall certify thereon, or in an     acknowledgment, proof or certificate of service, that the pleading was served within the     time period allowed by R. 4:6 or other rule specified in the certificate.

4:6-2. How Presented

  Every defense, legal or equitable, in law or fact, to a claim for relief in any     complaint, counterclaim, cross-claim, or third-party complaint shall be asserted in the     answer thereto, except that the following defenses may at the option of the pleader be     made by motion, with briefs: (a) lack of jurisdiction over the subject matter, (b) lack of     jurisdiction over the person, (c) insufficiency of process, (d) insufficiency of service     of process, (e) failure to state a claim upon which relief can be granted, (f) failure to     join a party without whom the action cannot proceed, as provided by R. 4:28-1. If a motion     is made raising any of these defenses, it shall be made before pleading if a further     pleading is to be made. No defense or objection is waived by being joined with one or more     other defenses in an answer or motion. Special appearances are superseded. If, on a motion     to dismiss based on the defense numbered (e), matters outside the pleading are presented     to and not excluded by the court, the motion shall be treated as one for summary judgment     and disposed of as provided by R. 4:46, and all parties shall be given reasonable     opportunity to present all material pertinent to such a motion.

4:6-3. Required Motions; Preliminary Hearings

  Defenses (a) (e) and (f) in R. 4:6-2, whether made in an answer or by motion,     shall be heard and determined before trial on application of any party, unless the court     for good cause orders that the hearing and determination thereof be deferred until the     trial. Defenses (b) (c) and (d) in R. 4:6-2 shall be raised by motion within 90 days after     service of the answer, provided that defense has been asserted therein and provided,     further, that no previous motion to which R. 4:6-6 is applicable has been made.

4:6-4. Motion for More Definite Statement or to Strike or Dismiss for Impropriety of     Pleading

  (a) More Definite Statement. If a responsive pleading is to be made to a     pleading which is so vague or ambiguous that a party cannot reasonably be required to     frame a responsive pleading, the party may move for a more definite statement before     interposing a responsive pleading. The motion shall point out the defects complained of     and the details desired. If the motion is granted and the order of the court not complied     with within 10 days after notice of the order or within such other time as the court     fixes, the court may strike the pleading to which the motion was directed or make such     order as it deems appropriate. The statement shall become a part of the pleading which it     supplements. (b) Impropriety of Pleading. On the court's or a party's motion, the court     may either (1) dismiss any pleading that is, overall, scandalous, impertinent, or,     considering the nature of the cause of action, abusive of the court or another person; or     (2) strike any such part of a pleading or any part thereof that is immaterial or     redundant. The order of dismissal shall comply with R. 4:37-2(a) and may expressly     require, as a condition of the refiling of a pleading asserting a claimor defense based on     the same transaction, the payment by the pleading party of attorney's fees and costs     incurred by the party who moved for dismissal.

4:6-5. Motion to Strike for Insufficiency

  On motion made by a party before responding to a pleading or, if no responsive     pleading is permitted by these rules, on motion made within 20 days after the service of     the pleading upon the party, or upon the court's own initiative at any time, the court may     order stricken from any pleading any defense insufficient in law.

4:6-6. Consolidation of Defenses

  A party making a motion under R. 4:6 may join with it the other motions herein     provided for and then available. If such motion omits therefrom any defense or objections     then available which R. 4:6 permits to be raised by motion, the party shall not thereafter     make a motion based on any such omitted defenses or objections, except as provided in R.     4:6-7.

4:6-7. Waiver or Preservation of Defenses

  Defenses (b) (c) and (d) in R. 4:6-2 are waived if not raised by motion pursuant     to R. 4:6-3 or if omitted from a previously made motion to which R. 4:6-6 is applicable.     Defenses (e) and (f) and an objection of failure to state a legal defense to a claim may     be made in any pleading permitted or ordered, or by motion for summary judgment or at the     trial on the merits. Whenever it appears by suggestion of the parties or otherwise that     the court lacks jurisdiction of the subject matter, the court shall dismiss the matter     except as otherwise provided by R. 1:13-4. Note: Source-R.R. 4:12-8.

Example of ANSWER, SEPARATE DEFENSES in a non- personal injury case:

  The defendant d1, doing business at d2   New Jersey, by way of Answer     to the plaintiff's Complaint, says:

  1.  He  admit the allegations of paragraph 1-

  2.  He admits all the allegations of paragraph 2 ...............and denies     the remaining paragraphs.

  3.  He admits the allegations of paragraph 3 .

  4.  He denies the allegations of paragraph ........

    WHEREFORE, Defendant demands judgment as follows:

  Dismissing the complaint, Denying all other requests by the plaintiff, for     Counsel Fees to be Awarded in Favor of Defendant pursuant to NJSA 2A:15-59.1 and Against     Plaintiff if Plaintiff does not immediately dismiss the Complaint and for such other     relief as the Court may deem just and equitable.

SEPARATE DEFENSES

Defendants reserve the right to assert the following defenses at trial

-The Complaint fails to state a claim upon which relief may be granted

-The claims in the Complaint are barred by the principles of waiver, Estelle and     Estelle

- The defendant acted on reasonable grounds with legal justification and therefore, are     not responsible to plaintiff in damages. -The claims set forth in the Complaint are barred     by the Doctrine of Accord and satisfaction, failure of consideration, illegality and     payment. - Breach of Contract - failure to Mitigate damages - Improper pleading by New     Jersey Corporation which must be represented by Attorney at Law in Superior Court -     Unconscionability of contract -Violation of Plain Language law - Lack of privity -     Improper pleading not conforming to Court Rules

Example of ANSWER, SEPARATE DEFENSES in a  personal injury case:

The defendant d1, doing business at ____, by way of Answer to the plaintiff's     Complaint, says:

  1.  Defendant d1 admits the operation and denies the balance

  2.  Defendant d1  admits

  3.  Defendant d1 admits the allegations of paragraph 3 .

  4.  Defendant d1 denies the allegations of paragraph 4

    WHEREFORE, Defendant d1 demands judgment as follows:

  Dismissing the complaint, Denying all other requests by the plaintiff, for     Counsel Fees to be Awarded in Favor of Defendant pursuant to NJSA 2A:15-59.1 and Against     Plaintiff if Plaintiff does not immediately dismiss the Complaint and for such other     relief as the Court may deem just and equitable.

                                   SEPARATE DEFENSES

Defendant d1 reserve the right to assert the following defenses at trial:

-The Complaint fails to state a claim upon which relief may be granted - The defendant     acted on reasonable grounds with legal justification and therefore, are not responsible to     plaintiff in damages. - failure to Mitigate damages - Improper pleading not conforming to     Court Rules -Defendant is free of negligence which was the proximate cause of the injuries     and damages alleged -Contributory negligence -Comparative negligence, per NJSA 2A:15-5.1     -Any and all Damages and/or personal injuries sustained by the plaintiff were the result     of the  acts and negligence of third persons or parties over whom the defendant     exercised no control. -The complaint is barred by the applicable Statute of Limitations     -The alleged incident complained of resulted from circumstances and conditions beyond the     control of the defendant. -The complaint alleges no violation of any duty that the     defendant may have owed to the plaintiff. -The damages alleged in the Complaint are barred     by the Entire  Controversy Doctrine. -All claims are barred by the Workers Comp Act     NJSA 34:15-8. -The defendant reserves the right to interpose such other defenses and     objections as continuing investigation may disclose. -The injuries and damages alleged in     the Complaint were caused by and arose out of risks which the plaintiff had full knowledge     of and assumed. -Defendant is immune from liability by NJSA 39:6A-8 - The action is barred     by NJSA 39:6A-1 - The action is barred by the verbal threshold statute.

                              CERTIFICATION THAT ANSWER FILED WITHIN TIME

  I hereby certify the Answer was served within the time permitted by law. I     certify that the matter in controversy is not the subject of any other action or     arbitration proceeding, now or contemplated, and that no other parties should be joined in     this action. R.4:5-1.       ANSWER TO ALL CROSS CLAIMS        The defendant d1 by way of any and all Cross claims, past, present and     future, says: The defendant d1, denies each and every material allegation of the cross     claims filed against him.

  CONCLUSION