NJSBA Family Law Section

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  • 1.  filing fee for answer to amended coutnerclaim

    Posted 02-02-2017 03:52 PM

    Counselors, Question.
    I had my answer to an amended counter claim held by finance for failure to pay the $175.00 fee in Bergen family. Susan in the finance dept is most helpful, but she is insisting my client has to pay for each successive answer to amended pleadings. I read the February 2015 fee update as requiring a fee for the "first responsive pleading". My take is you should pay for the first answer to a counterclaim, but not subsequent answers to (2nd, 3rd, ...10th) amended counterclaims. Anyone else run into this?

     

    Thomas R. King, Esq
    www.njfamily.law - www.njdivorce.law

     

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  • 2.  RE: filing fee for answer to amended coutnerclaim

    Posted 02-02-2017 03:56 PM

    Thomas,

      The court is wrong. They are making their own rules. Call the head administrator. If that doesn't work, Presiding Family Part judge. Then the Assignment judge.

    Ed

     

    * * *

    Edward J. Zohn, Attorney at Law

    Zohn & Zohn, LLP; 7 Mount Bethel Road, Warren NJ 07059

    908.791.0312 voice; 908.660.4866 fax

    "Leges sine moribus vanae" (Laws without morals are useless) - U. of Penna. Motto

    www.zohnlaw.com

     






  • 3.  RE: filing fee for answer to amended coutnerclaim

    Posted 02-02-2017 04:13 PM
    You could first try the Ombudsman.  I had similar issues in Union and the Ombudsman was helpful.
    Nancy Murray Horta, Esq.

     

    The Law Offices of Nancy Murray Horta, LLC

    21 Main Street, 
    Court Plaza South
    Suite 151
    Hackensack, New Jersey 07601

    Office: 201-308-5256   
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  • 4.  RE: filing fee for answer to amended coutnerclaim

    Posted 02-03-2017 11:30 AM

    Thomas:

     

    I have not run into this. There is not generally a fee to file an amended complaint or counterclaim so there should not be a fee to file an answer to the amended counterclaim.  I have filed amended complaints with no fee being charged. According to the statute, in fact, we are only supposed to be charged a filing fee for the first responsive pleading.  Despite that, the AOC took the position that an answer to counterclaim is a first responsive pleading to the counterclaim.

     

    In May, 2016, the Middlesex County Bar sponsored a meeting with Michelle Smith, Clerk of the Superior Court. The issue of being charged a fee to file an answer to a counterclaim was raised at that meeting, and she acknowledged to us that the charging of a fee for this seems to be contrary to the statute. I was hopeful that the current suit by the Passaic, Bergen and Middlesex County Bar Associations would include a challenge to the filing fees which we consider improper, but the associations chose to attack the fees based on a state constitutional basis.  The NJSBA decided not to intervene in the suit. It may be time to seek intervention by a group of attorneys with a more specific statutory view.

     

    I think Ms. Smith would agree that filing an answer to an amended counterclaim is not properly subject to a filing fee.  I urge you to call her (she told us she is open to all inquiries by phone) and let us know what she says.

     

    Robert E. Goldstein, Esq.
    Drescher & Cheslow, P.A.

    610 Bridge Plaza Drive

    Manalapan, NJ 07726

    (732) 972-1600
    Fax (732) 972-0038
    E-mail: [email protected]

     

    Visit my personal website:  www.mydivorcelawyernj.com

    Member, Middlesex County Bar Association,  Monmouth Bar Association, New Jersey Association for Justice and New Jersey State Bar Association

                                      

     

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