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defendant filed answer late / MTS


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I am in my second cc suit, the 1st was settled. I filed my answer/affirmative defenses past the 20 days given in NJ. Plaintiff filed a MTS my answer /affirmative defenses for failure to plead a defense, however I asserted many of the usual cc defenses.

defendants answer does not raise any defenses or issues of material fact and is insufficient in law pursuant to R.4:6-5 and R.6:3-1

Can I write an opposition asking for leniency? I also received via snail mail the MTS 2 days before I had to submit a response, so now I am also going to be late on sending the MTS.

How should I proceed?

Thank you!

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