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Complex Business Litigation Program

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The program and its rules are designed to better serve the litigation needs of New Jersey businesses by resolving complex business, commercial and construction cases in an expedited manner. Cases in the CBLP usually meet these criteria: 

  • Business or commercial transactions or construction projects that have complex factual or legal issues 
  • A large number of parties
  • Substantial discovery issues
  • Multiple experts
  • Implications for business beyond the decision in the particular case
  • Probable significant interpretation of a business or commercial statute


The program offers several benefits to lawyers and litigants:

Cases are managed by a skilled judge with experience complex business litigation. See the current roster.  Case management practices designed specifically for complex business litigation.


A case is automatically assigned to the CBLP if the amount in controversy is at least $200,000 and the litigants self-designate the case as complex commercial or complex construction. For a case not presumptively assigned to the program, litigants can file a motion requesting inclusion where the claim involves complex business-related issues and/or the amount in controversy is less than $200,000. Likewise, a motion can be made to exclude a case from the program. Whether pursuant to a motion, or on the judge’s own accord, the CBLP judge will review a case to determine whether the complex nature of the action or the threshold damages claim amount has been established. The case will then be included or removed from the CBLP, accordingly.

For questions, contact the  Civil Practice Division  at  609-815-2900 ext. 54900  or


Court Rule 4:102  Scope, Cognizability, and Administration

Court Rule 4:103  Case Management

Court Rule 4:104  Discovery

Court Rule 4:105  Motions 

Administrative Directive #01-19 – CBLP Guidelines and Model Forms and Orders 

CBLP Case Management Guidelines

Model Orders 

CBLP Model Joint Proposed Discovery Plan

CBLP Model Scheduling Order

CBLP Model eDiscovery Stipulation and Order

CBLP Model Clawback Stipulation and Order

Notices to the Bar

CBLP Resource Expansion January 2019

Directive #01-19 – CBLP Guidelines and Model Forms and Orders

Omnibus Rule Amendment Order

Additional Matters Eligible for CBLP Program Inclusion April 2018

CBLP Program Reminder April 2015

CBLP Implementation November 2014