Civil Court Rules and Jury Charges

Kenneth Vercammen & Associates, P.C.
2053 Woodbridge Avenue - Edison, NJ 08817

Thursday, August 27, 2009

Appendix XI-X - Verified Complaint – Nonpayment of Rent

APPENDIX XI-X. VERIFIED COMPLAINT – NONPAYMENT OF RENT

[Rule 6:3-4(c)]

Attorney(s)/Pro Se: _________________ SUPERIOR COURT OF NEW JERSEY
Office Address: ____________________ Law Division, Special Civil Part
Phone No.: ________________________ ______________ County
Docket No.: LT - ________________
Name of Plaintiff(s)/Landlord(s):
Civil Action

vs VERIFIED COMPLAINT
LANDLORD/TENANT
Name of Defendant(s)/Tenant(s):
___ Non-payment of Rent
___ Other (Required Notices Attached)


Address of Rental Premises: ______________________________________________________
Tenant’s Phone No.: ___________________

1. The owner of record is _______________________________________________.
(name of owner)

2. Plaintiff is the owner or (check one) ___agent, ___assignee, ___grantee or ___ prime tenant
of the owner.

3. The landlord __ did __ did not acquire ownership of the property from the tenant(s).

4. The landlord __ has __ has not given the tenant(s) an option to purchase the property.

5. The tenant(s) now reside(s) in and has (have) been in possession of these premises since ,
under (check one) __written or __oral agreement. (mm/dd/yyyy)

6. ___ Check here if the tenancy is subsidized pursuant to either a federal or state program or the rental unit is
public housing.

7. The landlord has registered the leasehold and notified tenant as required by N.J.S.A. 46:8-27.

8. The amount that must be paid by the tenant(s) for these premises is $_________, payable on the ___ day of
each __month or __week in advance.

COMPLETE PARAGRAPHS 9A AND 9B IF COMPLAINT IS FOR NON-PAYMENT OF RENT

9A. There is due, unpaid and owing from tenant(s) to plaintiff/landlord rent as follows:
$________ base rent for __________________________ (specify the week or month)
$________ base rent for __________________________ (specify the week or month)
$________ base rent for __________________________ (specify the week or month)
$________ late charge* for ________________________ (specify the week or month)
$________ late charge* for ________________________ (specify the week or month)
$________ late charge* for ________________________ (specify the week or month)
$________ attorney fees*
$________ other* (specify ___________)
$________ court costs (fees for filing and serving the complaint)
$________ TOTAL

*The late charges, attorney fees and other charges are permitted to be charged as rent for
purposes of this action by federal, state and local law (including rent control and rent
leveling) and by the lease.

9B. The date that the next rent is due is _________________.
(mm/dd/yyyy)
If this case is scheduled for trial before that date, the total amount you must pay to have this
complaint dismissed is $___________________.
(Total from line 9A)

If this case is scheduled for trial on or after that date, the total amount you must pay to have
this complaint dismissed is $_________________________________________________.
(Total from line 9A plus the amount of the next rent due)

These amounts do not include late fees or attorney fees for Section 8 and public housing
tenants. Payment may be made to the landlord or the clerk of the court at any time before the
trial date, but on the trial date payment must be made by 4:30 p.m. to get the case dismissed.

CHECK PARAGRAPHS 10 AND 11 IF THE COMPLAINT IS FOR OTHER THAN OR IN
ADDITION TO NON-PAYMENT OF RENT. ATTACH ALL NOTICES TO CEASE AND
NOTICES TO QUIT/DEMANDS FOR POSSESSION.

10. ___ Landlord seeks a judgment for possession for the additional or alternative reason(s)
stated in the notices attached to this complaint. STATE REASONS:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
(Attach additional sheets if necessary.)




11. ___ The tenant(s) has (have) not surrendered possession of the premises and tenant(s) hold(s)
over and continue(s) in possession without the consent of landlord.

WHEREFORE, plaintiff/landlord demands judgment for possession against the tenant(s) listed
above, together with costs.


DATED: _________________
_____________________________________________
(Signature of Filing Attorney or Landlord Pro Se)

_____________________________________________
(Printed or Typed Name of Attorney or Landlord Pro Se)


LANDLORD VERIFICATION


1. I certify that I am the ___ landlord, ___general partner of the partnership, or ___ authorized
officer of a corporation or limited liability company that owns the premises in which tenant(s)
reside(s).

2. I have read the verified complaint and the information contained in it is true and based on my
personal knowledge.

3. The matter in controversy is not the subject of any other court action or arbitration proceeding
now pending or contemplated and no other parties should be joined in this action except (list
exceptions or indicate none): ______________________________.

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


DATED: _________________
_____________________________________________
(Signature of Landlord, Partner or Officer)

_____________________________________________
(Printed Name of Landlord, Partner or Officer


[Note: Adopted as Appendix XI-X July 9, 2008 to be effective September 1, 2008.]