NEW JERSEY IS A FACT PLEADING STATE
Unlike Federal Courts that apply "notice" pleading, New Jersey is a "fact" pleading state.
Its Not Necessarily What You Learned In Law SchoolIn law school lawyers learned that civil pleadings in federal courts require only notifying the parties of the general issues in a case. In federal court the claims need only be asserted in general terms without alleging detailed facts in support of the claim. Federal courts apply what is commonly known as "notice" pleading. Because that's what lawyers learned in school many assume New Jersey is a notice pleading state. Not so. New Jersey Courts do not apply the same pleading standards as the federal courts.
Be Safe Plead The FactsNew Jersey is a "fact" pleading state.  The New Jersey Supreme Court has clarified that New Jersey is a fact pleading state. In Nostrame v. Santiago the appellate division unequivocally stated:
"New Jersey is a 'fact' rather than a 'notice' pleading jurisdiction,
which means that a plaintiff must allege facts to support his or her
claim rather than merely reciting the elements of a cause of action."
Nostrame v. Santiago, 420 N.J. Super. 427, 437 (App. Div. 2011). On appeal the New Jersey Supreme Court affirmed this legal principal in finding that the factual assertions were insufficient on the face of the complaint to state a claim for tortuous interference. See, Nostrame v. Santiago, 213 N.J. 109, 128 (2013).
The New Jersey Rules of Court State:
[A] pleading which sets forth a claim, counterclaim, cross-claim
or third party claim, shall contain a statement of the facts on which
the claim is based, showing the pleader is entitled to relief.
[emphasis added] R. 4:5-2. A complaint or counterclaim is not required to spell out the legal theory upon which it is based. Farese v. McGorry, 237 N.J. Super. 385, 390 (App. Div. 1989). Its necessary contents are only "a statement of the facts on which the claim is based, showing that the pleader is entitled to relief, and a demand for judgment for relief to which he deems himself entitled." Id. It has long been established that pleadings reciting mere conclusions without facts and reliance on subsequent discovery do not justify a lawsuit. Glass v. Suburban, 317 N.J. Super. 574, 582 (App. Div. 1998). A pleading must apprise the adverse party of the claims and issues to be raised at trial. Delbridge v. Office of Public Defender, 238 N.J. Super. 288, 312 (L. 1989). Pleadings are primarily fact based. Teilhaber v. Green, 320 N.J. Super. 453, 464 (App. Div. 1999). Pleading are required to apprise the adverse parties of the factual claims. The test for determining the adequacy of a pleading is limited to a review of the legal sufficiency of the facts on the face of the complaint. Print Mart v. Sharp Electronics, 116 N.J. 739, 746 (1989). Vague pleadings full of generalities may confuse and prejudice the adverse party who may understand the pleadings different from the pleader. Hewitt v. Hollahan, 56 N.J. Super. 372, 377 (App. Div. 1959). The court must search the complaint in depth and with liberality to determine if a cause of action can be gleamed even from an obscure statement of facts. Even though the standard is low, it is prudent to include sufficient facts in the complaint. In legal proceedings - if not in modern politics - the facts matter, and in New Jersey the facts matter from the get-go.