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A party served with a pleading stating a counterclaim or crossclaim against that party shall serve an answer thereto within 35 days after the service upon that party. A reply to an answer, where permitted, shall be served within 20 days after service of the answer.
Rule 4:7-2. A counterclaim may or may not diminish or defeat the recovery sought by the opposing party. It may claim relief exceeding in amount or different in kind from or not germane to that sought in the pleading of the opposing party.
An application to the court for an order shall be by motion, or in special cases, by order to show cause. A motion, other than one made during a trial or hearing, shall be by notice of motion in writing unless the court permits it to be made orally.
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Rule 1:6-4. Superior Court; Place for Filing Motions, Orders to Show Cause and Orders. The original of all motion papers, orders to show cause and orders in civil actions in the Superior Court shall be filed in ance with R.
2:6-4(e), shall have a buff cover, as shall any permitted subsequent brief of any other party. Covers of amicus briefs shall be green. Covers of all briefs and appendices shall be of a firm material but not glassine. The initial briefs of parties shall not exceed 50 pages and reply briefs shall not exceed 15 pages.
When service of a notice or paper is made by ordinary mail, and a rule or court order allows the party served a period of time after the service thereof within which to take some action, 5 days shall be added to the period. Rule 1:3-4.
4:6 permits to be raised by motion, the party shall not thereafter make a motion based on any such omitted defenses or objections, except as provided in R. 4:6-7. Defenses (b), (c) and (d) in R. 4:6-2 are waived if not raised by motion pursuant to R.
3d 496, 2020 N.J. LEXIS 348 (N.J. 2020). N.J. Ct. R. 4:6-2 gives a defendant the option to raise the enumerated defenses either by motion or in the answer; it does not prohibit the defendant from raising the defense of failure to state a cause of action in an answer.

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