I originally posted this at the bottom of another thread I had, but figured this should be separate - please post replies on this thread. ----------------------------------------------------------- Ok - so I'm back. I have a week to get this (my answer) to the court and plaintiff's attorney. Thank you everyone for your help thus far, especially Enigma who presented me with a draft answer to use -- My question has to do with the last two bullets of the draft for my affirmative defenses: ------------------------------------------------------------------ 2 . Pursuant to Rule XXXX XX Rules of Civil Procedure, Plaintiff failed to attach notes, bills of exchange, account statements, contracts, or other documents upon which an action may be brought. 3. Pursuant to Rule xxxx xxx Rules of Civil Procedure, the statute of Limitations has lapsed. This needs to be cleaned up for your local rules. ------------------------------------------------------------------- I'm not able to find clear (at least for my layperson self) Rules of Civil Procedure that state numbers 2 & 3 for NJ. Also - the statute of limitations had lapsed already by the time I moved to NJ (the SOL expired in TX) - how would I word that? THANKS!
