[// LEMON LAW COMPLAINT TEMPLATE — STATE OF NEW JERSEY ]
[// This template is drafted for use by licensed attorneys only. ]
[// It is designed for filing in the Superior Court of New Jersey, Law Division, and pleads claims under: ]
[// • New Jersey New Car Lemon Law, N.J. Stat. Ann. §§ 56:12-29 – 56:12-49 ]
[// • Magnuson-Moss Warranty Act, 15 U.S.C. §§ 2301 – 2312 (optional) ]
[// Customize all bracketed fields, verify facts, and conform to current court rules before filing. ]

IN THE SUPERIOR COURT OF NEW JERSEY

[COUNTY] VICINAGE – LAW DIVISION

DOCKET NO.: ___

[PLAINTIFF FULL NAME],
Plaintiff,

v.

[DEFENDANT MANUFACTURER LEGAL NAME],
Defendant.

Civil Action

COMPLAINT AND JURY DEMAND
(New Jersey Lemon Law — N.J.S.A. 56:12-29 et seq.)

TABLE OF CONTENTS

1. Parties ............................................................................ 2
2. Jurisdiction & Venue .......................................................... 2
3. Factual Allegations ............................................................. 3
4. Causes of Action
   Count I – Violation of New Jersey Lemon Law .............. 5
   Count II – Breach of Express Warranty .......................... 6
   Count III – Magnuson-Moss Warranty Act (Optional) ........ 7
5. Prayer for Relief ................................................................. 8
6. Certification Pursuant to R. 4:5-1 ....................................... 9
7. Designation of Trial Counsel ............................................ 9
8. Jury Demand .................................................................... 9
9. Certification & Verification (if required) ............................ 10

1. PARTIES

1.1 Plaintiff [PLAINTIFF FULL NAME] (“Plaintiff”) is an individual residing at [ADDRESS], County of [COUNTY], State of New Jersey.

1.2 Defendant [DEFENDANT MANUFACTURER LEGAL NAME] (“Defendant” or “Manufacturer”) is a corporation organized under the laws of [STATE], with its principal place of business at [ADDRESS], and authorized to transact business in New Jersey.

2. JURISDICTION & VENUE

2.1 This Court has subject-matter jurisdiction under N.J. Stat. Ann. §§ 56:12-29 – 49 and N.J. Ct. R. 4:3-1.

2.2 Venue is proper in this County pursuant to N.J. Ct. R. 4:3-2 because the transaction occurred and Plaintiff resides herein.

2.3 The amount in controversy, exclusive of interests and costs, does not exceed the statutory cap of the vehicle’s purchase price.

3. FACTUAL ALLEGATIONS

3.1 On or about [PURCHASE DATE], Plaintiff purchased a new [YEAR, MAKE, MODEL] motor vehicle, Vehicle Identification Number [VIN] (“Vehicle”), from [DEALERSHIP NAME], an authorized dealer of Defendant.

3.2 The purchase price of the Vehicle was [$____], inclusive of taxes, fees, and add-ons.

3.3 The Vehicle is a “motor vehicle” and “new motor vehicle” as defined in N.J.S.A. 56:12-30.

3.4 Defendant issued an express written warranty, valid for [TERM/MILEAGE], covering the Vehicle.

3.5 Beginning on or about [DATE], the Vehicle manifested one or more “nonconformities” within the meaning of N.J.S.A. 56:12-30, including but not limited to:
 a. [Describe Defect #1]
 b. [Describe Defect #2]

3.6 Plaintiff presented the Vehicle to Defendant’s authorized repair facility for correction of the nonconformities on at least [NUMBER] occasions, as detailed below:

3.7 Despite a “reasonable number of attempts” (N.J.S.A. 56:12-31(a)), the nonconformities persist and substantially impair the use, value, and/or safety of the Vehicle.

3.8 Pursuant to N.J.S.A. 56:12-32, Plaintiff provided Defendant written notice on [DATE] of the final opportunity to repair, by certified mail return receipt requested.

3.9 Defendant failed to correct the nonconformities within the statutorily prescribed 10-calendar-day final repair period.

3.10 Plaintiff has complied with all conditions precedent, including participation in [MANUFACTURER/NJ DCA] dispute-resolution program on [DATE(S)].
[// GUIDANCE: Participation is optional in NJ but can strengthen fee claim.]

4. CAUSES OF ACTION

COUNT I – Violation of New Jersey Lemon Law (N.J.S.A. 56:12-29 – 49)

4.1 Plaintiff repeats and realleges ¶¶ 3.1–3.10 as if set forth herein.

4.2 Defendant’s failure to correct the nonconformities after a reasonable number of attempts violates N.J.S.A. 56:12-31.

4.3 Plaintiff is entitled to:
 a. Repurchase of the Vehicle or replacement with a comparable new vehicle, at Plaintiff’s option;
 b. Refund of all collateral charges, taxes, and fees;
 c. Reasonable attorneys’ fees, expert fees, and costs, pursuant to N.J.S.A. 56:12-32(b).

COUNT II – Breach of Express Warranty (U.C.C. art. 2 adopted in N.J.S.A. 12A:2-313)

4.4 Plaintiff repeats ¶¶ 3.1–3.10.

4.5 Defendant expressly warranted the Vehicle to be free from defects in materials and workmanship.

4.6 The persistent nonconformities constitute a breach, proximately causing Plaintiff damages equal to at least the Vehicle’s purchase price and incidental costs.

COUNT III – Magnuson-Moss Warranty Act, 15 U.S.C. §§ 2301 – 2312 (Optional)

4.7 Plaintiff repeats ¶¶ 3.1–3.10.

4.8 The Vehicle is a “consumer product,” and Plaintiff a “consumer,” under 15 U.S.C. § 2301(3)–(1).

4.9 Defendant’s breach of its written warranty and failure to conform the Vehicle to same violates 15 U.S.C. § 2310(d).

5. PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment against Defendant as follows:

A. For Count I, an order directing Defendant to, at Plaintiff’s election, either:
 1. Replace the Vehicle with a new, comparable vehicle; or
 2. Repurchase the Vehicle and refund the full purchase price plus collateral charges;

B. For Counts II & III, compensatory damages not to exceed the purchase price, plus incidental and consequential damages;

C. Statutory attorneys’ fees, expert fees, and costs;

D. Pre- and post-judgment interest as allowed by law; and

E. Such other and further relief as the Court deems just and proper.

6. CERTIFICATION PURSUANT TO R. 4:5-1

I certify that, to the best of my knowledge, the matter in controversy is not the subject of any other action pending in any court or arbitration proceeding, nor is any other action or arbitration proceeding contemplated. I am unaware of any non-party who should be joined.

Date: _____                     
[ATTORNEY NAME], Esq.
Attorney for Plaintiff

7. DESIGNATION OF TRIAL COUNSEL (R. 4:25-4)

[ATTORNEY NAME], Esq., is hereby designated as trial counsel for Plaintiff.

8. JURY DEMAND

Plaintiff demands a trial by jury on all issues so triable.

9. CERTIFICATION & VERIFICATION (if Verified Complaint is desired)

[OPTIONAL—Include plaintiff’s notarized verification pursuant to R. 1:4-7.]

10. SIGNATURE BLOCK

Respectfully submitted,

[ATTORNEY NAME], Esq.
[LAW FIRM NAME]
[Address] | [Phone] | [Email]
Attorneys for Plaintiff

[// GUIDANCE: Attach the following as separate exhibits when filing]
• Exhibit A – Purchase Agreement / Bill of Sale
• Exhibit B – Repair Orders (chronological)
• Exhibit C – Certified-mail “final chance to repair” letter
• Exhibit D – Arbitration/ODR decision (if any)

[// GUIDANCE: Filing Checklist for NJ Superior Court]
1. Civil Case Information Statement (CIS)
2. Filing fee per R. 1:43
3. Completed summons for each defendant
4. Confidential personal identifiers redaction (R. 1:38-7)
5. E-Courts electronic submission