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Filing Fee for answer to counterclaim

  • 1.  Filing Fee for answer to counterclaim

    Posted 10-08-2015 11:41 AM

    I had previously posted about whether we must pay a filing fee of $175 for filing an answer to a counterclaim in a FM matter.

     

    Looks like the Superior Court clerk's office says yes, we do.

     

    I asked the Middlesex Family Division Manager, Chuck hager, who is great,  to get a definitive answer on this and he forwarded this response to me today:

    "Chuck,

    I spoke with Michelle Smith who indicates that there would be an answer fee of $175 and it is stated in the 2/27/15 notice to the bar which I have attached. It is headed under question #1. Let me know if there is anything else you need.

     

    Amy

    Amelia Wachter-Smith
    Family Practice Division
    609.984.0066"

    Ouch!!!

     

    Someone suggested a strategy to not file an answer to a counterclaim since the issues are joined in any event, but often different relief is being sought by the counterclaimant than what the plaintiff has sought, so I don't think that would be wise in most cases.



    ------------------------------
    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600
    ------------------------------



  • 2.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 12:01 PM
    that is just a wrong result. the plaintiff already paid to file, of course.
    this is not the 'first' pleading that the party is filing in the matter.



    any thoughts on how to push back on this? Anyone?



    Bob Davies



    Please send me an email to confirm that you received this email and that you
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    Sent on behalf of:

    Robert F. Davies, Esq.

    The Davies Law Firm, P.A.

    45 Essex Street, Suite 3 West

    Hackensack New Jersey 07601

    Phone: 201-820-3459

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  • 3.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 02:45 PM
    no attachment




  • 4.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 03:57 PM

    So why file it?

    The computer schedules the case management conference and other events when an answer (and/or counterclaim) is filed. Unless the case advances down the road to where a trial actually looks like a realistic option, why file it until absolutely necessary? Even if an adversary were to file for default on a counterclaim (and who's going to do that without mentioning it?), it'd be vacated.

    ------------------------------
    David Perry Davis, Esq.
    112 West Franklin Avenue
    Pennington, NJ 08534
    www.FamilyLawNJ.pro
    Voice: 609-737-2222
    Fax: 609-737-3222
    ------------------------------



  • 5.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 04:11 PM
    I had an adversary file a default on a counterclaim in a case which we were
    actively litigating.

    It cost several hours of work to get the motion filed (he would not consent
    to vacate).

    And under the logic of this requirement, you would STILL have to pay to file
    that Answer to Counterclaim, when you got the default vacated.







    Please send me an email to confirm that you received this email and that you
    can read it. Thank you!



    Sent on behalf of:

    Robert F. Davies, Esq.

    The Davies Law Firm, P.A.

    45 Essex Street, Suite 3 West

    Hackensack New Jersey 07601

    Phone: 201-820-3459

    Fax: 201-820-3461

    Email: <mailto:[email protected]> [email protected]

    Website: AttorneyRobertDavies.com



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  • 6.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 04:18 PM
    I looked up the filing fees for Answers to Counterclaims. I'm not sure
    they apply. The Rule (R. 1:43) states "Filing First Responsive Pleading in
    Dissolution Matter" is $175.00 (and refers to N.J.S.A. 22A:2-12). This is
    for the defendant's response.

    From what I could tell, N.J.S.A. 22A:2-12 reads (in relevant part):
    "
    22A:2-12. Payment of fees in Chancery Division of Superio Court upon filing
    of first paper.
    22A:2-12. Payment of fees in Chancery Division of Superior Court upon
    filing of first paper. Upon the filing of the first paper in any action or
    proceeding in the Chancery Division of the Superior Court, there shall be
    paid to the clerk of the court, for the use of the State, the following
    fees, which, except as hereinafter provided, shall constitute the entire
    fees to be collected by the clerk for the use of the State, down to the
    final disposition of the cause:

    ...

    Actions and proceedings for divorce or dissolution of a civil union,
    $300.00, $25.00 of which shall be forwarded by the Clerk of the Superior
    Court as provided in section 2 of P.L.1993, c.188 (C.52:27D-43.24a).
    "

    (The New Jersey Legislature web site does not reflect the recent amendments
    to the filing fees, so I updated the numbers).


    N.J.S.A. 22A:2-13 ("Answering, pleading or paper, fee") reads:
    "22A:2-13. Each person other than the plaintiff filing an answering
    pleading or other answering paper in the Chancery Division of the Superior
    Court shall at the time of filing the first paper, pay to the clerk the sum
    of $175.00; which shall cover all fees payable therein except such as may
    be otherwise provided herein or by law or the rules of court."

    (Again, I updated the amount of the fee since the NJ Legislature's web site
    did not reflect the current amount).

    This language indicates the filing fee for an Answer is not applicable to
    the Plaintiff, which makes sense and is how we've been handling it for
    years.

    However, as previously stated, the above rules and statutes appear to be in
    direct contravention to Judge Grant's Notices:

    Judge Grant's Notice to the Bar (
    http://www.judiciary.state.nj.us/notices/2015/n150227a.pdf) states there is
    a filing fee of $175.00 for Answers to Counterclaims, although that seems
    incongruous to the Statute. The justification by Judge Grant is that they
    are "made in response to a new cause of action." Judge Grant's previous
    "Clarification" for R. 1:43 (
    http://www.judiciary.state.nj.us/notices/2014/n141224a.pdf) states the
    "maximum fee charged for an answer or amended answer with a counterclaim,
    cross claim and/or third party complaint is $250". Again, all of these
    "clarifications" and statutes seem to contradict each other, although Judge
    Grant's most recent statement is $175 for an Answer to a Counterclaim, so I
    assume that's why some people are being charged.

    Apologies for the formatting, these were copied and pasted from some
    e-mails I had sent.


    Gregory Thomlison, Esq.
    Law Office of Stacey D. Kerr, Esq.
    650 Washington St.
    Suite 1C
    Toms River, NJ 08753
    Ph. (732) 736-8100

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    reply to this email. Thank you.

    On Thu, Oct 8, 2015 at 4:11 PM, Robert Davies via New Jersey State Bar




  • 7.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 04:19 PM
    We just filed an Answer to Counterclaim on 2 separate files in the last month in Hunterdon County....no fees to file. $175 is the Answer fee (or first paper on behalf of defendant). I think the court personnel misunderstood the question they were asked.



    Therese H. Thompson, Esq.
    39 Main Street
    Clinton, NJ 08809
    (908) 238-0401
    Fax (908) 238-0403

    _______________________________________________________________________
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  • 8.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 04:21 PM
    I have never paid a filing fee with an answer to a counterclaim.

    Jeffrey S. Karl PA
    Jeffrey S. Karl, Esq.
    1820 Chapel Avenue West
    Suite 195
    Cherry Hill, NJ 08002
    Phone (856) 486-0707
    Fax (856) 488-5690
    www.jeffreyskarl.com




  • 9.  RE: Filing Fee for answer to counterclaim

    Posted 10-08-2015 05:16 PM
    I was advised today that the Superior Court Clerk has instructed all family
    division managers to make sure that the $175 filing fee is paid before
    filing an answer to counterclaim.



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


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  • 10.  RE: Filing Fee for answer to counterclaim

    Posted 10-09-2015 06:56 AM

    At the Ocean County Bar Family Law Committee meeting in September they (the presiding judge and division manager) advised that the filing fee is $175 for answers to counterclaims.  

    I had the fee returned to me by Burlington that same month.

    I think the fee is absurd considering the increased cost for the complaint.


    ------------------------------
    Rachel Cotrino Esq.
    Jackson NJ
    (732)987-9966
    ------------------------------




  • 11.  RE: Filing Fee for answer to counterclaim

    Posted 10-09-2015 09:07 AM

    Hunterdon County Central Fee Office just clarified....in Law Division there is a $175 fee to file an Answer to Counterclaim.  In Chancery (Family) there is no fee to file an Answer to Counterclaim.

     

    Therese H. Thompson, Esq.
    39 Main Street
    Clinton, NJ 08809
    (908) 238-0401
    Fax (908) 238-0403

    _______________________________________________________________________
    CONFIDENTIALITY NOTICE: This email contains information that is privileged and confidential and subject to legal restrictions and penalties regarding its' unauthorized disclosure or other use.  You are prohibited from copying, distributing or otherwise using this information if you are not the intended recipient.  If you have received this email in error, please notify us immediately by return email and delete this email and all attachments from your system.






  • 12.  RE: Filing Fee for answer to counterclaim

    Posted 10-09-2015 11:31 AM

    That is not what the Middlesex Family Division manager told me and not what the memo to the division managers from Amy Wachter-Smith in the Family Division of the AOC sent out to all family division managers. The court notice on the court website also does not distinguish between divisions of the Superior Court regarding the charge.

     

     

     

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

         

     

    IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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    .

     






  • 13.  RE: Filing Fee for answer to counterclaim

    Posted 10-09-2015 11:57 AM

    Spoke with Atlantic County Family Division yesterday was  told they will now be charging the $175.00 for an answer to a counterclaim for divorce.

    Spoke with Cape May FM team leader as well yesterday and they said they are not charging for an answer to a cc.  These two counties are in the same vicinage. 

     

    My two cents for now.  Never a dull moment!!!

     

    Marla Marinucci, Esq.

    Certified by the Supreme Court of New Jersey

    as a Matrimonial Law Attorney

    RUSSELL LAUGHLIN & MARINUCCI, PA

    117 Atlantic Avenue

    Ocean City, NJ  08226

    (609) 398-1900

    Fax: (609) 398-7292

    Email: [email protected]

     

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  • 14.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 09:13 AM

    All:  This is certainly an area of great concern to the Family Law Section.  We started working on related issues several months ago when the Court initially published the new fee schedule.   The NJSBA is fully aware of our concerns about the impact on family law litigants and we are confident that the officers and Board of Trustees are doing all that they can to get our collective concerns addressed. 

    ------------------------------
    Amanda Trigg Esq.

    Chair, Family Law Section of the NJSBA (2015-16)
    Hackensack NJ
    (201)488-1161
    ------------------------------




  • 15.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 09:28 AM
    How is this not in direct contravention to the statute?

    N.J.S.A. 22A:2-13 ("Answering, pleading or paper, fee") reads:
    "22A:2-13. Each person other than the plaintiff filing an answering
    pleading or other answering paper in the Chancery Division of the Superior
    Court shall at the time of filing the first paper, pay to the clerk the sum
    of $175.00; which shall cover all fees payable therein except such as may
    be otherwise provided herein or by law or the rules of court." (totals updated since the Legislature's version appears to not reflect the current amounts)


    Gregory Thomlison, Esq.
    Law Office of Stacey D. Kerr, Esq.
    650 Washington St.
    Suite 1C
    Toms River, NJ 08753
    Ph. (732) 736-8100

    THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS ATTORNEY-PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION ARE STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, Please immediately notify us by telephone or reply to this email.  Thank you.

    On Thu, Oct 15, 2015 at 9:14 AM, Amanda Trigg via New Jersey State Bar Association






  • 16.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 10:34 AM

    Anyone want to organize to fight this?

     

    Clearly, our clients are getting hit for additional fees that should not be there.

    Only makes sense if the whole Family Section of the NJ Bar fights this.

     

     

    Please send me an email to confirm that you received this email and that you can read it.  Thank you!

     

    Sent on behalf of:

    Robert F. Davies, Esq.

    The Davies Law Firm, P.A.

    45 Essex Street, Suite 3 West

    Hackensack New Jersey 07601

    Phone: 201-820-3459

    Fax:     201-820-3461

    Email: [email protected]

    Website: AttorneyRobertDavies.com

     

    CONFIDENTIALITY NOTICE:

    This email and any accompanying attachments contains information which

    may be confidential and privileged. If you are not the addressee (or

    authorized to receive this message for the addressee), you are not

    authorized to read, use, copy or disclose this message or any part of it

    to anyone. If you have received this message in error, please notify the

    sender immediately by e-mail and delete all copies of this message.

    Thank you.

     






  • 17.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 10:43 AM

    NJSBA is on it.

     

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

         

     

    IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

    Privileged Information: This message, together with any attachments, is intended only for the use of the individual or entity to which it is addressed and may contain information that is legally privileged, confidential and/or exempt from disclosure. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please delete this message, along with any attachments, from your computer. Thank you
    .

     






  • 18.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 09:30 AM
    Thanks, Amanda.

    Robert E. Goldstein, Esq.
    Drescher & Cheslow, P.A.
    (732) 972-1600
    [email protected]

    Visit my website: www.mydivorcelawyernj.com




  • 19.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 06:29 PM


    Are the new fees reflected in a court rule? If there is a conflict between a statute and a rule, the statute wins if the statute addresses a matter of "substance." Rules are limited to addressing issues of "practice and procedure." So is a filing fee a matter of "substance" or "practice and procedure"? The below is a little off-topic, but it covers the point if anyone is researching it in reference to a potential challenge.

    If the new fee schedule is a Directive, then it's even clearer - Directives don't go through essentially any review process and are supposed to be limited to directing internal court processes.

    I could be wrong (that happened once in the mid-90's), but I thought there was a statute that specifically permitted the court to establish court fees?


    David Perry Davis, Esq.
    ----------------------------------------------------
    www.FamilyLawNJ.pro
    ----------------------------------------------------
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax: 609-737-3222


    To the extent defendants are arguing here that court Rules permitting the issuance of warrants (and resulting suspensions) "without further notice" override the legislative scheme for notice and an opportunity to be heard before a suspension is imposed, it would constitute a conflict between Directive #15-08 and N.J.S.A. 2A:17 56.41. The suspension of a license is a matter of substance, not procedure. The clear legislative intent is that a suspension be imposed only on notice and only as the result of a hearing wherein its coercive effect is explored. For a Directive to instead provide for the issuance of a warrant "without further notice" upon a mere default on a two week warrant status order with no inquiry whatsoever as to whether the default was willful is an intrusion into the area of substantive law, the exclusive providence of the legislature.

    When there is a conflict between a Directive and a statute on an area of substantive law, the former must yield to the latter. See State v. Maurer, 438 N.J.Super. 402 (App.Div. 2014) (in a conflict between AOC Directive as to admission to Drug Court program and a revision to the statute, the Directive must yield as substantive rights implicated). See also, New Jersey Constitution, Article VI, § 2, ¶ 3 ("the Supreme Court shall make rules governing the administration of all courts in the State and, subject to law, the practice and procedure in all such courts."), Winberry v. Salisbury, 5 N.J. 240, 245 46, cert. denied, 340 U.S. 877 (1950) (Emphasis added), In re P.L. 2001, Chapter 362., 186 N.J. 368, 380 (2006) (defining "pleading and practice" as opposed to substance).

    While the legislature did not establish criteria for when a warrant should issue, it was abundantly clear that the consequence of magnitude of a suspension should not be imposed casually. It entrusted the responsibility for determining when warrants as opposed to summonses should be issued to the AOC. Rather than promulgating a Directive that adheres to the clearly expressed legislative intent that a suspension be ordered only after notice and a reasonably contemporaneous hearing to explore the reason for a default and to establish that this action would be coercive, Directive #15-08 established a process whereby a warrant can be entered on nothing more than a belief "that bringing an obligor before the court on an expedited basis will be necessary"(Exhibit A at page 6). For the Directive to permit the entry of a warrant (and, therefore a suspension) "without further notice" upon a mere default is an improper intrusion into the legislature's exclusive authority to determine such substantive policies.

    ------------------------------
    - Dave

    David Perry Davis, Esq.
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax: 609-737-3222



  • 20.  RE: Filing Fee for answer to counterclaim

    Posted 10-19-2015 04:09 PM


    It was suggested to me today that if you represent a plaintiff, you put a catchall phrase or provision (as if you were pleading sdeparate defense, for example) wherein you deny the allegations of any counterclaim that may be filed, as a way of getting around having to file an answer to counterclaim and getting charged the $175 filing fee.

    This seems silly but maybe it will work.

    ------------------------------
    Robert Goldstein Esq.
    Manalapan NJ
    (732)972-1600



  • 21.  RE: Filing Fee for answer to counterclaim

    Posted 10-15-2015 02:11 PM
    Thanks, Amanda.

    Robert E. Goldstein, Esq.
    Drescher & Cheslow, P.A.
    (732) 972-1600
    [email protected]

    Visit my website: www.mydivorcelawyernj.com