NJSBA Family Law Section

 View Only

Latest on answer to counterclaim filing fee

  • 1.  Latest on answer to counterclaim filing fee

    Posted 01-08-2016 12:38 PM

    Dear Colleagues:

    In a case where my client, the plaintiff, filed a complaint for divorce based on irreconcilable differences, and the defendant filed a counterclaim also based on irreconcilable differences, I recently attempted to file an Appearance with regard to the counterclaim.

    We received the document back filed, but somebody from the court wrote on it "Answer to cc" and billed our Superior Court account $175.00 rather than the $50.00 fee for an appearance.

    The statutory authority for the charge of filing fees in Chancery Division of Superior Court is found in N.J.S.A. 22A:2-12 specifically states: "Upon the filing of the first paper in any action or proceeding in the Chancery Division of the Superior Court ... (emphasis added). Doesn't this show that it was the Legislature's intent to assess a fee to each litigant when the litigant files his or her first pleading? If so, the filing of a successive pleading (such as an answer to a counterclaim or an appearance to a counterclaim) should not result in the charging of an additional filing fee as the litigant has already paid his or her "entrance" fee to be involved in the litigation.

    In addition, N.J.S.A. 2B:1-7(a) authorizes the Court to revise or supplement a fee which N.J.S.A. 22A:2-12 authorizes. I submit that an answer or appearance filed in response to a counterclaim is not a revision or supplementation of fees payable to the court but rather an entirely new fee that was never charged prior to the rule change to court rule 1:43.

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


  • 2.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 01:32 PM
    What county?  I confirmed with both Morris and Sussex that they will not charge for any pleading filed in response to the Counterclaim, because it is not a first pleading.  Only first pleadings are charged.



    Very truly yours,
    Siobhan Mary Fuller, Esq.
    176 Morris Street, First Floor
    Morristown, NJ 07960



    CONFIDENTIALITY NOTICE

    This e-mail message and any attachments from the above named law office is intended only for the individual or entity to which it is addressed and is covered by the Electronic Communications Privacy Act, 18 U.S.C. Sec 2510 et.seq. . This e-mail may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you received this e-mail by accident, please notify the sender immediately and destroy this e-mail, any attachments and all copies of it.  PLEASE TAKE FURTHER NOTICE THAT: The law firm in forwarding requested information and or responding to received email does not and cannot warrant or insure the privacy and or applicable privilege beyond warnings set forth, supra.  In the event that an email response or notification has been requested by client, the client is advised that in requesting said electronic email correspondence may be effective waiver of claim of putative privilege, if any,  as to email, content and attachments, hereto. The Law Firm's policy is that we DO NOT practice law via e-mail, in the regular course of representation. 

    IRS Circular 230 Disclosure: Unless expressly stated otherwise, any U.S. tax advice contained in this communication (including any attachments) was not written and is not intended by the Law Firm to be used, and cannot be used, for the purpose of (i) avoiding penalties imposed by the Internal Revenue Code or (ii) promoting, marketing, or recommending any transaction or matter addressed herein. 






  • 3.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 01:39 PM
    Meanwhile, I was recently in Middlesex and was advised that, per the AOC, all courts should be charging for filing a responsive pleading to a Counterclaim.  


    Very truly yours,  

    NANCY B. MARCHIONI
    241 Cook Avenue
    Middlesex, NJ  08846
    Telephone (732) 667-3668
    Facsimile (732) 667-3669
    Cellular (908) 917-1493
    EMAIL: [email protected]
     
    Treasury Regulations require us to inform you that any Federal
    tax advice contained in this communication is not intended and
    cannot be used for the purpose of: (i) avoiding tax related
    penalties under United States law; or (ii) promoting,
    marketing or recommending to another party any transaction or
    matter addressed herein. The contents of this e-mail may be
    protected, by the attorney-client privilege or may otherwise be
    privileged or confidential. If you are not the intended
    recipient, any further disclosure or use, dissemination,
    distribution, printing or copying of this e-mail or any
    attachment hereto, is prohibited. If you have received
    this e-mail in error, please notify us immediately so that we may
    correct our internal records, and then delete the original e-
    mail.
    All e-mail sent to or from the Law Firm of Nancy B. Marchioni is
    subject to monitoring by its members. Unauthorized interception
    of this e-mail is a violation of Federal and New Jersey State Laws.
    IMPORTANT DISCLAIMER: This email is not offered nor intended as, nor should it be construed as,
    the offer of legal advice nor presentation nor statement of applicable law nor rules applicable to any
    claims that the recipient of this email may presently have or may have had.  






  • 4.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 01:42 PM

    Middlesex

     

    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
    .

     






  • 5.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 01:51 PM

    The counties need to get on the same page.






  • 6.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 02:02 PM
    Bergen county is charging a fee for an Answer to Counterclaim of $175.00. I confirmed with the assignment judges team that the fee is being charged in accordance with the AOC directive.

    Nancy Murray Horta, Esq.

    Sent from my iPhone




  • 7.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 02:09 PM

    what happens if we all agree to not default each other for failing to answer counterclaims?

     

    sorry, I am just getting a little bit frustrated here. what nonsense.

     

    the Bar Association is/is not seriously fighting this?

    David Perry Davis having any success dealing with this?

     

    Bob Davies

     

    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

     

     






  • 8.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 02:17 PM

    I just had a case in Somerset County where my adversary chose not to file an Answer to Counterclaim to avoid paying the filing fee. The matter was scheduled for dismissal.  Hard to understand why, when they had filed the Complaint, and I had answered, doesn't that constitute joinder? When we called to ask, we were told that it was standard practice.

     

    Marion Solomon

     

    Marion B. Solomon, Esq.

    Arons & Solomon, PA

    One University Plaza

    Hackensack, NJ 07601

    201-342-7610

     

    [email protected]

     

     






  • 9.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 02:24 PM

    dismissal of the Complaint if you do not answer the counterclaim……nice.

     

    obviously not the most critical issue in our practices, but still irritating and illogical.

     

     

     

     






  • 10.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 02:36 PM

    Agreed, but I would hate to have to explain to the client why their matter was dismissed…

     

    Marion

     

    Marion B. Solomon, Esq.

    Arons & Solomon, PA

    One University Plaza

    Hackensack, NJ 07601

    201-342-7610

     

    [email protected]

     

     






  • 11.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 03:25 PM

    Here's the issue, Mr. Davies. Assume the following:

     

    You represent Husband. You file on husband's behalf a complaint for divorce based on irreconcilable differences and seek a divorce and joint legal and physical custody of the children.

     

    Wife goes to me and says that Husband is an ogre and was physically and verbally abusive to both her and the kids for years, and no way should husband have shared or even joint legal custody. As a result, I file on wife's behalf an extreme cruelty counterclaim that contains 7 pages of detailed cruelty allegations which, if true, would have a strong impact on a custody decision.

     

    Would any one of us not file an answer to that 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

         

     

    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
    .

     






  • 12.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 03:50 PM

    agree, then you file the answer, and pay the money.

     

    my gripe is the simple fact that the case is already in court, and filing an answer to your counterclaim does not in any way create any additional effort on the part of the court system.

     

    why should an additional fee be paid?

     

    perhaps there is a line of reasoning that I have not figured out for myself.

     






  • 13.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 04:18 PM

    Why not skip the court house all together and arbitrate your case?

     

     

    Noel S. Tonneman, Esq.

     

    THIS MESSAGE MAY CONTAIN PRIVILEGED AND CONFIDENTIAL INFORMATION. IT IS INTENDED ONLY FOR THE USE OF THE PERSON OR ENTITY TO WHOM IT IS ADDRESSED.  IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US BY TELEPHONE AT 732-696-2500 AND DELETE THIS EMAIL. 

     

    YOUR EMAIL IS IMPORTANT TO ME.  HOWEVER, I AM NOT ALWAYS ABLE TO ANSWER EMAILS ON THE DAY THEY ARE RECEIVED.  IF YOUR MATTER IS TIME SENSITIVE, PLEASE CONTACT MY OFFICE AT 732-696-2500 AND SPEAK WITH MY STAFF DIRECTLY.  THANK YOU.

     






  • 14.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 04:19 PM
    Or better yet, mediate. Bonnie Blume Goldsamt 

    Bonnie Blume Goldsamt, MA, JD, APM
    NJ and NY Attorney
    Federal Dist Court of NJ Mediator
    NJ Superior Court Approved Rule 1:40 Mediator 
    Private Divorce & Civil Mediator 
    Mediation Trainer
    Arbitrator
    Collaborative Law Professional 

    25 Pompton Avenue, Suite 101
    Verona, NJ  07044
    - and -
    (973) 857-6220 tel
    One University Plaza, Suite 14
    Hackensack, NJ  07601






  • 15.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 04:37 PM

    Or better yet, reconcile. :=)


    hanan.gif

    Hanan M. Isaacs, Esq.

     

    t 609.683.7400   f 609.921.8982

    e [email protected]   w www.hananisaacs.com

    4499 Route 27, Kingston NJ


    IMPORTANT NOTICE: This email transmission and any documents, files, or email messages attached to it, are confidential and protected by the attorney client privilege and/or work product doctrine. If you are not NJSBA_familylaw_19f2b6e5-9698-4766-8d27-abda47d5ab48@ConnectedCommunity.org, or a person responsible for delivering it to the intended recipient, then we hereby notify you that any review, disclosure, copying, dissemination, distribution, or use of any of the information contained in or attached to this email transmission is STRICTLY PROHIBITED. If you have received this transmission in error, then please immediately notify [email protected] by email -- or by fax to (609) 921-8982 -- or by telephone to (609) 683-7400 -- and then promptly delete the message and any attachments from your computer. Thank you.






  • 16.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 05:05 PM
    Sue the bastards!

    Sent from my iPhone




  • 17.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 04:56 PM
    Or collaborate!

    Anna-Maria Pittella
    Sent from my iPhone




  • 18.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 05:23 PM

    Anna-Maria:

     

    I was waiting for one of our group to chime in. Hope to see you on Tuesday evening.

     

    The truth is that while all of the alternative dispute resolution forms are great for a lot of cases, there are some cases that have to go to court.

     

    I just think it's outrageous that a plaintiff in a divorce case is being charged about $500 in filing fees, while the defendant has to pay $175.  And don't get me started on the $25 to put a gold sticky on a divorce judgment!

     

    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
    .

     






  • 19.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 07:38 PM

    From today's law journal:  NJ Lawmakers Consider Fee Hikes to Fund Courthouse Security

    Read more: http://www.njlawjournal.com/id=1202746659673/NJ-Lawmakers-Consider-Fee-Hikes-to-Fund-Courthouse-Security#ixzz3whdvZgYK


    ....Yup. They're looking at increasing them further. Maybe they'll even up the costs to defendants now?



    <x-sigsep>

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

    </x-sigsep>





  • 20.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 08:47 PM
    Again these are matters that can be negotiated in mediation or collaboration. They can agree to share the pain. 

    Anna-Maria Pittella
    Sent from my iPhone





  • 21.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 03:14 PM

    I can tell you that Chuck Hager, our Middlesex County Family Division Manager, who is a great guy, shared with the Middlesex Bar's family law section a memo from the AOC to ALL county division managers stating that they must collect the $175 fee for 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

         

     

    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
    .

     






  • 22.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 04:49 PM
    In a couple of counties, if you file an appearence as to the counterclaim, they don't charge the $175. I'm sure they'll catch on to that eventually.

    My continuing gripe is that the fee waiver process was supposed to be better publicized, and solid guidelines as to when waivers should be granted were supposed to be announced. Neither has happened. Many people don't even know a fee waiver process exists.

    I suppose it's all motivation to resolve cases more quickly - before the dismissal threat for failure to failure to file an answer to the counterclaim comes through.

    Or, here's another couple ideas:
    <x-tab>        </x-tab>• File FD complaints (no fee), then let the adversary counterclaim for divorce, which automatically converts the FD to an FM.
    <x-tab>        </x-tab>• Get a written agreement that the marital estate is capped, work out a PSA/MSA, then file for a Mexican divorce since the filing fee is $22 and they don't have a residency requirement. Domesticate the judgment only if enforcement is needed.
    <x-tab>        </x-tab>• Start a non-profit devoted to providing legal services, have all clients filed initial pleadings through it (or Legal Services), since the fees are waived. Then substitute in.
    <x-tab>        </x-tab>• Ask the legislature defund the judiciary completely until the stop with the $175 nonsense fee.


    <x-sigsep>

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

    </x-sigsep>





  • 23.  RE: Latest on answer to counterclaim filing fee

    Posted 01-08-2016 05:09 PM
    Another issue with all of this nonsense is that it also creates a much heavier financial burden on the Plaintiff.  The cost for filing the Complaint (assuming no children) is  $300.  The Defendant pays $175 to file the responsive pleadings.  If the Defendant files a counterclaim, the Plaintiff now has to shell out another $175, costing the Plaintiff $475 in filing fees as opposed to the $175 for the Defendant. 


    Very truly yours,  

    NANCY B. MARCHIONI
    241 Cook Avenue
    Middlesex, NJ  08846
    Telephone (732) 667-3668
    Facsimile (732) 667-3669
    Cellular (908) 917-1493
    EMAIL: [email protected]
     
    Treasury Regulations require us to inform you that any Federal
    tax advice contained in this communication is not intended and
    cannot be used for the purpose of: (i) avoiding tax related
    penalties under United States law; or (ii) promoting,
    marketing or recommending to another party any transaction or
    matter addressed herein. The contents of this e-mail may be
    protected, by the attorney-client privilege or may otherwise be
    privileged or confidential. If you are not the intended
    recipient, any further disclosure or use, dissemination,
    distribution, printing or copying of this e-mail or any
    attachment hereto, is prohibited. If you have received
    this e-mail in error, please notify us immediately so that we may
    correct our internal records, and then delete the original e-
    mail.
    All e-mail sent to or from the Law Firm of Nancy B. Marchioni is
    subject to monitoring by its members. Unauthorized interception
    of this e-mail is a violation of Federal and New Jersey State Laws.
    IMPORTANT DISCLAIMER: This email is not offered nor intended as, nor should it be construed as,
    the offer of legal advice nor presentation nor statement of applicable law nor rules applicable to any
    claims that the recipient of this email may presently have or may have had.  






  • 24.  RE: Latest on answer to counterclaim filing fee

    Posted 01-09-2016 12:14 PM
    Just file FD's. Into court quicker. Less paperwork, resolve issues and convert to an FM for put through purposes.   They have to deal with you for $25. An application. 

    Sent from my iPhone





  • 25.  RE: Latest on answer to counterclaim filing fee

    Posted 01-09-2016 06:37 PM
    I was kind of kidding when I suggested that this (filing FD's and then converting to FM) would be a way to go, but hey ... why not? If the client's funds are that tight, we could do it that way. Just make sure there's a written agreement between counsel to cap the marital estate - as we went through a few months ago, only the filing of a complaint that results in a judgment of divorce otherwise does so (...potential malpractice alert).



    <x-sigsep>

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

    </x-sigsep>





  • 26.  RE: Latest on answer to counterclaim filing fee

    Posted 01-12-2016 05:10 PM

    At least it won't be getting worse any time in the future --

    Fee Hike Proposal Dies as Senate Fails to Act

     

    A bill that sought to increase some court filing fees, fines and penalties in order to enhance security measures at New Jersey's local and county courthouses has died­at least for the time being. Read More »


    <x-sigsep>

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

    </x-sigsep>