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A party's admission may be used as affirmative substantive evidence against that party. Evid.R. 63(7); Stoelting v. Hauck, 32 N.J. 87, 106, 159 A.2d 385 (1960). Consistent with that premise, evidence of a defendant's guilty plea is admissible as an admission in a civil action. Kellam v. Akers Motor Lines, 133 N.J.L. 1, 3, 42 A.2d 261 (E. & A. 1945); Mead v. Wiley Methodist Episcopal Church, 23 N.J.Super. 342, 349-50, 93 A.2d 9 (App.Div.1952); see IV Wigmore on Evidence § 1066 at 82 n. 7 (1972) (Wigmore). In particular, guilty pleas to traffic offenses are admissible in civil suits to establish liability arising from the same occurrence. Kellam, supra, 133 N.J.L. at 3, 42 A.2d 261; Liberatori v. Yellow Cab Co., 35 N.J.Super. 470, 476-77, 114 A.2d 469 (App.Div.1955); see also cases cited in Wigmore, supra, § 1066 at 82 n. 7. By contrast, a record of conviction for a non-indictable offense is inadmissible in such an action. See N.J.S.A. 2A:81-12; Burd v. Vercruyssen, 142 N.J.Super. 344, 353, 361 A.2d 571 (App.Div.1976); Mead, supra, 23 N.J.Super. at 351, 93 A.2d 9. 

Unlike a party who has ...

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