New Jersey § 26:2h-39

§ 26:2h-39.

The complaint shall: a. (1) Set forth material facts showing that there exists in the boarding or nursing

home a condition or conditions in substantial violation of the standards of health,

safety or resident care established under Federal or State law or regulations or any

other conditions dangerous to life, health or safety or (2) that there exists in the

boarding or nursing home a pattern and practice of habitual violation of the standards

of health, safety or patient care established under Federal or State law or regulations. b. Set forth that the facts set forth in subsection a. of this section have been brought

to the attention of the owner and licensee of the home and that the condition or conditions

have not been remedied within a reasonable period of time or that the condition or

conditions although periodically remedied habitually exists in the home as pattern

and practice. c. Set forth a brief description of what is necessary to remedy the condition and

an estimate of the cost thereof. d. State the relief sought.