VIOLETTE, Justice.
In February 1979, plaintiff Oliver began this action against Martin for assault. Two years later, Martin was ordered defaulted for his failure to file a timely responsive pre-trial memorandum. After a hearing on damages in Superior Court, Cumberland County, judgment was entered for compensatory and punitive damages against Martin. On appeal, Martin raises several alleged errors. We vacate the judgment and remand for a new hearing on punitive damages...
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