Tenant Answer and Affirmative Defenses to Summary Dispossess Complaint — New Jersey

TENANT ANSWER AND AFFIRMATIVE DEFENSES TO SUMMARY DISPOSSESS COMPLAINT — NEW JERSEY

TABLE OF CONTENTS

1. Caption
2. General Denial / Specific Responses
3. Affirmative Defenses
4. Counterclaims and Setoffs
5. Marini Habitability Defense — Rent Deposit
6. Demand for Hardship Stay (Conditional)
7. Demand for Trial; Reservation of Rights
8. Verification (R. 1:4-7)
9. Certification of Service
10. Tenant's Statement of Rights and Disclosures
11. Trial Checklist for the Tenant
12. New Jersey Practice Notes
13. Sources and References

1. CAPTION

SUPERIOR COURT OF NEW JERSEY

LAW DIVISION — SPECIAL CIVIL PART

LANDLORD/TENANT SECTION

[________________________________] COUNTY

DOCKET NO. LT-[________________________________]

TENANT'S VERIFIED ANSWER, AFFIRMATIVE DEFENSES, COUNTERCLAIMS, AND DEMAND FOR HARDSHIP STAY

Civil Action

Defendant [TENANT NAME] ("Tenant"), by way of answer to the Verified Tenancy Complaint of Plaintiff [LANDLORD NAME] ("Landlord"), pleads as follows:

2. GENERAL DENIAL / SPECIFIC RESPONSES

2.1. Parties (Complaint ¶¶ 2.1–2.4).

☐ Admitted as to identity of Tenant and address of Premises.
☐ Denied that Plaintiff is the owner of record. Tenant demands strict proof and identification of the actual owner of record. R. 6:3-4(a).
☐ Denied that Plaintiff is the duly authorized agent of the owner.
☐ Without knowledge or information sufficient to admit or deny.

2.2. Jurisdiction and Venue (Complaint ¶¶ 3.1–3.3). Admitted that the Premises are located in [________________________________] County, New Jersey. The remaining allegations are conclusions of law to which no response is required; to the extent a response is required, denied.

2.3. Tenancy and Lease (Complaint ¶¶ 4.1–4.6).

☐ Admitted that Tenant occupies the Premises as a residential tenant.
☐ Denied as to alleged terms / rent amount / lease date.
☐ Denied that the Premises are exempt from the Anti-Eviction Act. Tenant asserts that the Anti-Eviction Act applies and Plaintiff has failed to plead a valid enumerated ground.
☐ Denied that the Premises are properly registered as required by N.J.S.A. § 46:8-28; absent valid registration, no nonpayment action may be maintained per N.J.S.A. § 46:8-33.
☐ Denied that a current lead-safe certification has been obtained for pre-1978 Premises.

2.4. Grounds for Removal (Complaint ¶¶ 5.1–5.2). Each statutory ground asserted is denied. Tenant specifically denies:

☐ That rent is due in the amount alleged. The actual amount due (if any) is $[____] because [setoff / abatement / payment / waiver / other].
☐ That Tenant engaged in disorderly conduct or any conduct destructive of the peace and quiet of others.
☐ That Tenant willfully or by gross negligence damaged the Premises. Any damage is the result of Landlord's failure to maintain.
☐ That Tenant substantially breached any lease covenant. The Lease lacks a "void on breach" clause required for eviction under § 2A:18-61.1(e).
☐ That a Notice to Cease was served, was sufficient, or afforded a reasonable cure period.
☐ That Tenant habitually pays rent late.
☐ That Plaintiff (or Plaintiff's purchaser) has a good-faith intent to personally occupy the Premises.
☐ That a valid conversion has been registered with the NJ DCA.
☐ Other denial: [________________________________].

2.5. Notice and Demand (Complaint ¶¶ 6.1–6.5).

☐ Denied that the Notice to Cease (where required) was timely served, was specific, or afforded a reasonable cure period.
☐ Denied that the Notice to Quit was served in accordance with statute.
☐ Denied that the statutory notice period under N.J.S.A. § 2A:18-61.2 has elapsed.
☐ Without knowledge or information sufficient to admit or deny.

2.6. Compliance with Collateral Statutory Requirements (Complaint ¶ 7.1–7.6).

☐ Denied. Plaintiff has not distributed the Truth in Renting statement.
☐ Denied. The multifamily registration is not current.
☐ Denied. The Premises lack a current lead-safe certification.
☐ Denied. Plaintiff has not complied with federal Section 8 / public-housing pre-eviction procedures.

2.7. Self-Help and Retaliation (Complaint ¶¶ 8.1–8.2). Tenant specifically alleges that Plaintiff has engaged in retaliatory conduct as set forth in the Affirmative Defenses below.

3. AFFIRMATIVE DEFENSES

By way of separate and additional defense, and pleading in the alternative, Tenant asserts the following Affirmative Defenses:

3.1. Failure to State a Claim Under the Anti-Eviction Act

Plaintiff has failed to plead any of the eighteen (18) enumerated grounds for eviction under N.J.S.A. § 2A:18-61.1, which are exclusive. Mere expiration of the Lease term is not a ground for eviction of a covered residential tenant. The Complaint should be dismissed under R. 4:6-2.

3.2. Defective Notice to Cease (Where Required)

Pursuant to N.J.S.A. § 2A:18-61.2 and A.P. Dev. Corp. v. Band, 113 N.J. 485 (1988), grounds (b), (d), (e), and (j) require a sufficient Notice to Cease prior to any Notice to Quit. The Notice to Cease in this matter is defective because:

☐ It was never served;
☐ It failed to specify the offending conduct with sufficient particularity;
☐ It failed to identify the lease provision or rule allegedly violated;
☐ It failed to afford a reasonable cure period;
☐ It was combined with a simultaneous Notice to Quit, defeating its purpose.

3.3. Defective Notice to Quit

The Notice to Quit is defective because:

☐ It was not served in accordance with statute;
☐ The notice period required by N.J.S.A. § 2A:18-61.2 had not elapsed before commencement of this action;
☐ It failed to identify the statutory ground;
☐ It failed to afford the required cure period;
☐ It contains material misstatements of fact or law.

3.4. Marini Habitability Defense (Implied Warranty of Habitability)

Pursuant to Marini v. Ireland, 56 N.J. 130 (1970), and Berzito v. Gambino, 63 N.J. 460 (1973), the Premises are subject to an implied warranty of habitability. Plaintiff has breached that warranty in the following respects:

The reasonable rental value of the Premises in their defective condition is $[____] per month — substantially less than the contract rent of $[____]. Tenant requests a Marini hearing to determine the abated rental value and to credit the difference against any arrears found to be due.

3.5. Repair-and-Deduct Setoff

Tenant gave Plaintiff timely and adequate notice of the defective conditions on [__/__/____]. Plaintiff failed to make repairs within a reasonable time. Tenant accordingly engaged in self-help repairs at a cost of $[____], which is set off against any rent claim. Marini v. Ireland, 56 N.J. at 146.

3.6. Reprisal / Retaliation (N.J.S.A. § 2A:42-10.10)

This action is brought in unlawful reprisal for Tenant's exercise of legal rights, including:

☐ Good-faith complaint to a governmental authority of health or safety violations on [__/__/____] (Department: [________________________________], Complaint No. [____]);
☐ Exercise of right under the Lease, including a request for repairs on [__/__/____];
☐ Joining or organizing a tenant organization;
☐ Filing or testifying in a proceeding involving the Landlord;
☐ Other protected activity: [________________________________].

Pursuant to N.J.S.A. § 2A:42-10.12a, Tenant invokes the rebuttable presumption of retaliation that arises where the Landlord brings an eviction action after the Tenant's exercise of rights.

3.7. NJLAD Discrimination — Source of Income (N.J.S.A. § 10:5-12.5)

Plaintiff has discriminated against Tenant on the basis of source of lawful income, including but not limited to:

☐ Section 8 Housing Choice Voucher;
☐ Project-Based Section 8 subsidy;
☐ State Rental Assistance Program (SRAP);
☐ Social Security / SSI / SSDI;
☐ Child support / alimony;
☐ Veterans benefits;
☐ Other lawful source: [________________________________].

Such discrimination violates N.J.S.A. § 10:5-12 and § 10:5-12.5 (as amended January 12, 2026). The action should be dismissed and Tenant is entitled to attorney fees and damages under N.J.S.A. § 10:5-13.

3.8. Discrimination on Other Protected Bases (NJLAD)

This action is the product of unlawful discrimination on the basis of:

☐ Race / color / national origin / ancestry;
☐ Familial status (e.g., presence of children);
☐ Disability (failure to provide reasonable accommodation);
☐ Religion;
☐ Sex / gender identity / sexual orientation;
☐ Domestic-violence-victim status (N.J.S.A. § 46:8-9.6);
☐ Age;
☐ Other protected class: [________________________________].

3.9. Multifamily Registration Failure (N.J.S.A. § 46:8-33)

The Premises are within a multiple dwelling required to be registered under the Hotel and Multiple Dwelling Law, and Plaintiff has failed to maintain a current Certificate of Registration. Accordingly, no action for nonpayment of rent may be maintained. Lemon v. Aronson Properties, LLC, ___ N.J. Super. ___ .

3.10. Lead-Safe Certification Failure (P.L. 2021, c. 182)

The Premises were constructed before 1978 and Plaintiff has failed to obtain a current lead-safe certification as required by N.J.S.A. § 52:27D-437.16. Plaintiff is therefore subject to penalties and the equities preclude possessory relief.

3.11. Federal Subsidized-Housing Pre-Eviction Procedures (24 C.F.R. Pts. 247, 982, 966)

The Premises are subsidized through [Section 8 Voucher / Project-Based Section 8 / Public Housing / LIHTC], and Plaintiff has failed to comply with the applicable federal pre-eviction notice, grievance, and good-cause requirements before commencing this action. The action is preempted and must be dismissed.

3.12. Senior Citizen / Disabled Protected Tenancy (N.J.S.A. § 2A:18-61.22 et seq.)

Tenant is a senior citizen aged sixty-two (62) or older / a person with a qualifying disability, and has resided at the Premises as a principal residence for at least one year. Tenant has applied (or hereby applies) for Protected Tenancy status with [Local Protected Tenancy Agency / NJ DCA]. Pending and during such status, no action for possession may proceed under conversion grounds.

3.13. Bad Faith / False Certification (N.J.S.A. § 2A:18-61.6)

If Plaintiff proceeds under § 2A:18-61.1(L)(1), (L)(2), (L)(3), or (m), Tenant alleges that Plaintiff (or Plaintiff's purchaser) does not have a good-faith intent to personally occupy or convert the Premises and that the certification is false. Tenant reserves the right to seek treble damages and attorney fees under § 2A:18-61.6.

3.14. Tender of Rent / Right to Cure (N.J.S.A. § 2A:18-55)

Tenant has tendered (or stands ready to tender) all rent due plus statutory court costs at any time before judgment, which entitles Tenant to dismissal under § 2A:18-55. The trial will not occur until [__/__/____], and tender will be made by 4:30 p.m. on the trial date if not earlier.

3.15. Waiver and Estoppel

Plaintiff has waived strict performance of the Lease term(s) at issue by:

☐ Accepting late rent payments without complaint over an extended period;
☐ Acquiescing in the conduct now alleged as a breach;
☐ Continuing to accept rent after the Notice to Quit;
☐ Other: [________________________________].

3.16. Self-Help Eviction (N.J.S.A. § 2A:39-1)

Plaintiff has engaged in unlawful self-help by:

☐ Changing the locks on [__/__/____];
☐ Shutting off utilities on [__/__/____];
☐ Removing Tenant's personal property on [__/__/____];
☐ Threatening, harassing, or intimidating Tenant.

Tenant is entitled to treble damages and attorney fees under N.J.S.A. § 2A:39-8 and to dismissal of this action.

3.17. Domestic Violence Victim Protection (N.J.S.A. § 46:8-9.6 to -9.12)

Tenant is a victim of domestic violence and the conduct alleged by Plaintiff is the result of (or related to) the domestic violence. Tenant invokes the protections of N.J.S.A. § 46:8-9.6 et seq. (early lease termination; non-eviction).

3.18. Failure to Plead Owner; R. 6:3-4(a)

The Complaint fails to identify the actual owner of record and the relationship of the named Plaintiff to the owner. The Complaint must therefore be dismissed.

3.19. Unconscionability / Adhesive Lease Provisions

The Lease provisions sought to be enforced are unconscionable, surprise, or contrary to public policy and are therefore unenforceable.

3.20. Reservation of Additional Defenses

Tenant reserves the right to assert additional defenses as may be revealed by discovery, investigation, or trial preparation, and as may be permitted under R. 6:5 (oral pleading at trial in summary tenancy actions).

4. COUNTERCLAIMS AND SETOFFS

4.1. First Counterclaim — Breach of Implied Warranty of Habitability

Plaintiff breached the implied warranty of habitability as detailed in Affirmative Defense 3.4 above. Tenant has paid rent in excess of the abated value of the Premises in the amount of $[____], which Tenant is entitled to recover as a setoff and/or judgment. Berzito v. Gambino, 63 N.J. 460 (1973).

4.2. Second Counterclaim — Security Deposit Violations (N.J.S.A. § 46:8-19 to -26)

Plaintiff has failed to:

☐ Provide written notice within 30 days of the depository institution and amount of the security deposit;
☐ Pay annual interest on the deposit;
☐ Hold the deposit in a separate interest-bearing account.

Tenant seeks the statutory remedy of double damages plus attorney fees and costs under N.J.S.A. § 46:8-21.1.

4.3. Third Counterclaim — Self-Help Eviction (N.J.S.A. § 2A:39-1; § 2A:39-8)

If Plaintiff has engaged in self-help as alleged in Affirmative Defense 3.16, Tenant seeks treble damages, restoration of possession, attorney fees, and costs.

4.4. Fourth Counterclaim — Reprisal (N.J.S.A. § 2A:42-10.10)

Tenant seeks damages, declaratory relief, and attorney fees for unlawful reprisal as alleged in Affirmative Defense 3.6.

4.5. Fifth Counterclaim — NJLAD Discrimination (N.J.S.A. § 10:5-12; § 10:5-13)

Tenant seeks compensatory and punitive damages, declaratory relief, attorney fees, and costs for unlawful discrimination as alleged in Affirmative Defenses 3.7 and 3.8.

4.6. Sixth Counterclaim — False Certification under § 2A:18-61.6

If Plaintiff prevails on a (L)(1), (L)(2), (L)(3), or (m) ground but the certified intent is not carried out within reasonable time, Tenant reserves a separate cause of action for treble damages and attorney fees.

5. MARINI HABITABILITY DEFENSE — RENT DEPOSIT

5.1. Tenant has tendered (or hereby tenders) $[____] into the Court (Special Civil Part Clerk) representing the undisputed portion of the rent in dispute, in support of Tenant's Marini habitability defense and to demonstrate good faith. See Drew v. Pullen, 172 N.J. Super. 570 (App. Div. 1980).

5.2. Tenant respectfully requests:

(a) An evidentiary hearing pursuant to Marini to determine the rental value of the Premises in their defective condition;

(b) An order directing Plaintiff to make specified repairs;

(c) An order abating the rent retroactively from [__/__/____] through the date of cure;

(d) Such other relief as the Court deems just.

6. DEMAND FOR HARDSHIP STAY (CONDITIONAL)

6.1. Demand for Hardship Stay. In the event the Court enters a Judgment for Possession, Tenant respectfully requests, pursuant to R. 6:6-6 and N.J.S.A. § 2A:42-10.6, a hardship stay of execution of the Warrant of Removal for a period of up to six (6) months on the following grounds:

☐ Children of school age would be displaced mid-year;
☐ Tenant or a member of Tenant's household has a serious medical condition requiring stable housing;
☐ Tenant has a pending application for state or federal rental assistance;
☐ Tenant has a pending Section 8 voucher transfer / portability request;
☐ Tenant is a senior citizen or disabled person seeking alternative housing;
☐ Other hardship: [________________________________].

6.2. Conditions. Tenant agrees to pay use and occupancy at the rate of $[____] per month into the Court Clerk during any stay period.

6.3. Order for Orderly Removal. Alternatively, Tenant requests an Order for Orderly Removal under R. 6:6-6 affording Tenant additional time to vacate.

7. DEMAND FOR TRIAL; RESERVATION OF RIGHTS

7.1. Tenant demands trial by the Court on all issues, with the right to present testimony, documentary evidence, and witness testimony.

7.2. Tenant reserves the right to amend this Answer to add or modify defenses and counterclaims as discovery and trial preparation reveal.

7.3. Tenant reserves the right to seek an adjournment of trial to obtain counsel through the Newark Office of Tenant Legal Services, the Jersey City Right to Counsel Program, Legal Services of New Jersey, or otherwise.

☐ Tenant appears pro se.

8. VERIFICATION (R. 1:4-7)

I, [________________________________], hereby verify and certify pursuant to R. 1:4-7 that:

8.1. I am the Tenant/Defendant in the foregoing matter and have personal knowledge of the facts set forth in this Answer, Affirmative Defenses, and Counterclaims.

8.2. The factual allegations are true based upon my personal knowledge, except as to those allegations made on information and belief, and as to those matters I believe them to be true.

8.3. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment.

Sworn and subscribed before me this [____] day of [____________], 20[__].

Notary Public / Attorney at Law of NJ: [________________________________]
Commission Expires: [__/__/____]

9. CERTIFICATION OF SERVICE

I hereby certify that on [__/__/____], I caused a true copy of the foregoing Tenant's Answer, Affirmative Defenses, Counterclaims, and Demand for Hardship Stay to be served upon Plaintiff and Plaintiff's counsel by:

☐ U.S. First-Class Mail, postage prepaid;
☐ U.S. Certified Mail, Return Receipt Requested, Article No. [________________________________];
☐ Hand delivery;
☐ eCourts upload pursuant to R. 1:32-2A;
☐ Other (specify): [________________________________].

10. TENANT'S STATEMENT OF RIGHTS AND DISCLOSURES

10.1. Right to Cure (N.J.S.A. § 2A:18-55). In any nonpayment action, Tenant may obtain dismissal by tendering all rent due plus statutory court costs at any time before judgment, and as a matter of course before 4:30 p.m. on the trial date.

10.2. Three-Business-Day Stay (R. 6:6-3). Even if a Judgment for Possession is entered, no Warrant of Removal may issue until three (3) business days have passed; once executed, Tenant gets three (3) more business days before lockout.

10.3. Hardship Stay (R. 6:6-6; N.J.S.A. § 2A:42-10.6). Up to six (6) months stay of execution available on hardship grounds.

10.4. Right to Counsel.
☐ Newark, NJ: Newark residents at or below 200% of federal poverty level have a right to free counsel through the Newark Office of Tenant Legal Services. Phone: 973-733-3675.
☐ Jersey City, NJ: Right to counsel under Jersey City Ordinance 23-046. https://www.righttocounseljc.org.
☐ Statewide: Legal Services of New Jersey LSNJ-LAW: 1-888-LSNJ-LAW (1-888-576-5529); https://www.lsnjlaw.org.

10.5. Self-Help Forbidden (N.J.S.A. § 2A:39-1; § 2A:39-8). Landlord may NOT lock you out, remove your possessions, or shut off utilities; treble damages available.

10.6. Security Deposit (N.J.S.A. § 46:8-19 et seq.). Within 30 days after termination, Landlord must return deposit + interest, less itemized lawful deductions; double damages for wrongful withholding.

10.7. Anti-Eviction Act (N.J.S.A. § 2A:18-61.1 et seq.). Landlord must prove a valid statutory ground; expiration of lease alone is NOT a ground.

10.8. Truth in Renting (N.J.S.A. § 46:8-43 et seq.). Landlord must distribute the NJ DCA Truth in Renting statement to tenants in covered buildings.

10.9. Marini Habitability. You may defend a nonpayment action by proving the Premises were uninhabitable and seek rent abatement.

10.10. Reprisal Protection (N.J.S.A. § 2A:42-10.10). Eviction in retaliation for protected tenant activity is unlawful.

10.11. Discrimination Protection (NJLAD). Eviction based on race, source of income, disability, familial status, etc. is unlawful and is a defense and counterclaim.

10.12. Senior / Disabled Protected Tenancy (N.J.S.A. § 2A:18-61.22 et seq.). Up to 40 years of protection in conversion situations may apply.

10.13. Domestic Violence Protection (N.J.S.A. § 46:8-9.6). Victims have early termination and non-eviction rights.

11. TRIAL CHECKLIST FOR THE TENANT

☐ Bring photo ID.
☐ Bring lease (if any) and all written communications with landlord (texts, emails, certified mail receipts).
☐ Bring rent receipts, money order stubs, bank statements showing rent payments.
☐ Bring all notices received from landlord (Notice to Cease, Notice to Quit, Demand for Rent).
☐ Bring photographs/videos of habitability defects, with dates.
☐ Bring records of repair requests (texts, emails, certified mail).
☐ Bring records of complaints to municipal code enforcement / health department.
☐ Bring receipts for repair-and-deduct expenses.
☐ Bring proof of source of income (Section 8 voucher, SSI award letter, etc.) where source-of-income discrimination is alleged.
☐ Bring witnesses (neighbors, family members, maintenance personnel).
☐ Bring sufficient funds (cash, certified check, money order) to tender rent + costs at trial if invoking right to cure under § 2A:18-55.
☐ Arrive at courthouse at least one (1) hour before scheduled trial time.
☐ Check in with the Landlord/Tenant clerk; confirm appointment of counsel if eligible.
☐ Do NOT sign any consent judgment, settlement, or stipulation without consulting counsel.

12. NEW JERSEY PRACTICE NOTES

12.1. Oral pleading at trial. R. 6:5 permits a tenant to "appear and state a defense" orally at trial without a pre-trial written answer. Tenants who file a written Answer like this one nevertheless preserve the same defenses. Some judges encourage written submissions; many tolerate oral defenses in pro se cases.

12.2. Pretrial motions. Tenants may file a Motion to Dismiss before trial under R. 4:6-2 where the complaint is facially defective (wrong owner, missing notice, missing registration, no statutory ground). These are heard on the trial date typically.

12.3. Marini hearing. If habitability is asserted, the court will typically conduct an evidentiary hearing on the same day as trial or schedule an adjourned hearing date. Tenant should be prepared to deposit the disputed rent into court to preserve the defense. Drew v. Pullen, 172 N.J. Super. 570 (App. Div. 1980).

12.4. Right to cure. N.J.S.A. § 2A:18-55 grants an absolute right to cure in nonpayment actions through 4:30 p.m. on the trial date by tendering all rent due plus statutory court costs ($45-65 typically). Tender to the Clerk of the Special Civil Part is sufficient; the case is then dismissed.

12.5. Three-business-day stay. Even after judgment, no warrant issues for 3 business days; once executed, lockout is delayed another 3 business days. R. 6:6-3.

12.6. Hardship stay. Up to 6 months under R. 6:6-6 and N.J.S.A. § 2A:42-10.6. School-year displacement, medical needs, pending Section 8 transfer or rental assistance, and senior/disabled status are recognized hardships.

12.7. Right to counsel — local programs. Newark Office of Tenant Legal Services and Jersey City Right to Counsel can appoint counsel on the day of trial. Eligibility is income-based. Tenants statewide can call LSNJ-LAW for advice.

12.8. Rent escrow. Some judges direct tenants to pay rent into court during contested proceedings; failure to comply has been a basis for striking habitability defenses. Tender voluntarily where appropriate.

12.9. Subsidized housing. Federal pre-eviction notice and grievance procedures (24 C.F.R. Parts 247, 982, 966) are independent of state law and may bar a state-court eviction not preceded by federal compliance.

12.10. Source-of-income amendment (January 12, 2026). The NJLAD amendment effective January 12, 2026 provides comprehensive definitions of source of lawful income and prohibits financial standards not based on the tenant's portion of rent. Income-screening discrimination is a defense and counterclaim.

12.11. Settlement caution. Tenants should NOT sign consent judgments without counsel. Many "consent to enter judgment" stipulations waive rights to appeal, hardship stay, and habitability defenses.

12.12. Appeals. A judgment for possession is appealable to the Appellate Division within 45 days. Notice of appeal does not automatically stay execution; a separate motion for stay pending appeal must be made. R. 2:9-5.

13. SOURCES AND REFERENCES

• N.J.S.A. § 2A:18-53 (Summary dispossess): https://law.justia.com/codes/new-jersey/title-2a/section-2a-18-53/
• N.J.S.A. § 2A:18-55 (Tenant's right to cure): https://law.justia.com/codes/new-jersey/title-2a/
• N.J.S.A. § 2A:18-61.1 (Anti-Eviction Act): https://law.justia.com/codes/new-jersey/title-2a/section-2a-18-61-1/
• N.J.S.A. § 2A:18-61.2 (Notice periods): https://www.njleg.state.nj.us/
• N.J.S.A. § 2A:18-61.6 (Owner liability — treble damages): https://law.justia.com/codes/new-jersey/title-2a/section-2a-18-61-6/
• N.J.S.A. § 2A:18-61.22 et seq. (Senior/Disabled Protected Tenancy): https://law.justia.com/codes/new-jersey/title-2a/section-2a-18-61-22/
• N.J.S.A. § 2A:39-1 et seq. (Self-help bar): https://law.justia.com/codes/new-jersey/title-2a/
• N.J.S.A. § 2A:42-10.6 (Hardship stay): https://law.justia.com/codes/new-jersey/title-2a/
• N.J.S.A. § 2A:42-10.10 to .14 (Reprisal Law): https://www.nj.gov/dca/codes/publications/pdf_lti/reprisal_law.pdf
• N.J.S.A. § 46:8-9.6 et seq. (Domestic Violence Tenant Protections): https://law.justia.com/codes/new-jersey/title-46/
• N.J.S.A. § 46:8-19 to -26 (Rent Security Deposit Act): https://www.nj.gov/dca/codes/publications/pdf_lti/sdepsit_law.pdf
• N.J.S.A. § 46:8-28; § 46:8-33 (Multifamily registration): https://law.justia.com/codes/new-jersey/title-46/
• N.J.S.A. § 46:8-43 et seq. (Truth in Renting Act): https://www.nj.gov/dca/codes/publications/pdf_lti/truth_rent_act.pdf
• N.J.S.A. § 10:5-12.5 (NJLAD source of income): https://www.njoag.gov/about/divisions-and-offices/division-on-civil-rights-home/know-the-law/njlad/discrimination-in-housing/
• N.J.S.A. § 52:27D-437.16 (Lead-Safe Certification): https://www.nj.gov/dca/codes/resources/leadpaint.shtml
• Marini v. Ireland, 56 N.J. 130 (1970): https://law.justia.com/cases/new-jersey/supreme-court/1970/56-n-j-130-0.html
• Berzito v. Gambino, 63 N.J. 460 (1973): https://law.justia.com/cases/new-jersey/supreme-court/1973/
• A.P. Dev. Corp. v. Band, 113 N.J. 485 (1988): https://law.justia.com/cases/new-jersey/supreme-court/1988/
• Drew v. Pullen, 172 N.J. Super. 570 (App. Div. 1980): https://law.justia.com/cases/new-jersey/appellate-division-published/1980/
• R. 6:5 (Defendant's pleadings): http://www.courtcaddy.com/nj/court-rules/r6-5.html
• R. 6:6 (Judgment / Warrant of Removal): http://www.courtcaddy.com/nj/court-rules/r6-6.html
• NJ Courts Landlord-Tenant Self-Help: https://www.njcourts.gov/self-help/landlord-tenant
• NJ DCA Grounds for Eviction Bulletin: https://www.nj.gov/dca/codes/publications/pdf_lti/grnds_for_evicti_bulltin.pdf
• NJ DCA Eviction Law Bulletin: https://www.nj.gov/dca/codes/publications/pdf_lti/evic_law.pdf
• LSNJ Defenses to Eviction: https://www.lsnjlaw.org/Housing/Landlord-Tenant/Evictions/Pages/Defenses-to-Eviction.aspx
• LSNJ-LAW: 1-888-LSNJ-LAW; https://www.lsnjlaw.org
• Newark Office of Tenant Legal Services: https://ecode360.com/36623969
• Right to Counsel JC: https://www.righttocounseljc.org

END OF TENANT ANSWER