In Schettino v. Roizman Development, 158 N.J. 476, 488, 730 A.2d 797 (1999), the Court's primary focus was on the impact of the Offer of Judgment rule where there are multiple defendants, and only one of the defendants offers to take judgment against itself for its pro rata share of the verdict. Id. at 478, 730 A.2d 797. Because the provisions of Rule 4:58-3 did not clearly address that issue, the Court recommended the Civil Practice Committee to address it. Id. at 489, 730 A.2d 797. However, in light of the fact that the trial judge entered a summary judgment against the claimant in that case, the Court also observed: Yet another issue concerns the prohibition under Rule 4:58-3 of awarding counsel fees against a plaintiff who does not recover a judgment of at least $ 750. The prohibition is paradoxical. A plaintiff who fails to recover anything is not subject to such an award, but one who recovers more than $ 750 may be obligated to pay counsel fees. Id. at 488-89, 730 A.2d 797.