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hurts my client’s ability to rent in the future. I am also concerned of the risk of Plaintiff being deemed the prevailing party and awarded attorney’s fees (even though no Motion for Fees has been filed nor an affidavit). This was a wrongful eviction to begin with, but I was hired after my client filed her answer/aff defenses and had already scheduled NJT, so I was not able to amend pleading. I do intend on filing separate lawsuit against landlord for breaches/violations of duty. Again, they are pro se, so I am not too concerned, but I am curious: should I file a Notice or Motion? With Motion, I can request to hear it during time we have already scheduled for trial to fight to type of ruling/judgment I desire.
Any suggestions, tips, advice, etc. would be so greatly appreciated! TYIA!