General Provisions as to Pleadings

(a) Counsel tendering a pleading gives his assurance as an officer of the court that it is filed in good faith and not for delay. (b) A pleading that is sworn to is an affidavit for all purposes for which an affidavit is required or permitted. (c) Counsel or an unrepresented party who files a pleading must sign it and state his address. (d) Every pleading must state the facts on which the party relies in numbered paragraphs, and it is sufficient if it clearly informs the opposite party of the true nature of the claim or defense. (e) An allegation of fact in a pleading that is not denied by the adverse party's pleading, when the adverse party is required by these Rules to file such pleading, is deemed to be admitted. A denial must fairly respond to the substance of the allegation. A party that intends in good faith to deny only part of an allegation must admit the part that is true and deny the rest. An allegation in a pleading that the party does not know whether a fact exists will be treated as a denial that the fact exists. (f) Requirements of pleadings applicable to instruments not under seal apply to instruments under seal. (g) Requirements of pleadings applicable to legal defenses apply to equitable defenses. (h) The clerk must note and attest the filing date on every pleading. In an Electronically Filed Case, the procedures of Rule 1:17 apply to the notation by the clerk of the date of filing. (i) The mention in a pleading of an accompanying exhibit, of itself and without more, makes such exhibit a part of the pleading. Filing of such exhibits is governed by