2013-04-26T13:58:46-05:00 Insurance defense counsel often refuses to answer discovery. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. State your full name, your present address, and date of birth. COURTS on-line Subscriber Change Form(fillable): this form needs to be completed if an existing COURTS on-line subscriber has had a change to their name or e-mail address or if their e-filing access level request has changed. Sample Interrogatories Posted on March 11, 2010 by Neil Garfield A special thanks to Neil Garfield for all the great research and work he has done and continues to do, to help homeowners fight to save their homes from foreclosure fraud. A .gov website belongs to an official government organization in the United States. 2. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. The PLAINTIFF requests that the DEFENDANT produce the following documents and things in your possession, custody or control in accordance with Rules 26 and 34 of the North Carolina Rules of Civil Procedure for inspection and copy at the offices of A-5298-07T25298-07T2. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. 7. Think about the hard questions that you would like to get answers to read to a jury. But the total number of requests cannot exceed thirty. Follow instructions on the form. The objections are, of course, drafted by the attorney. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Rule 4:17-3. 21. Plaintiffs' complaint was dismissed with prejudice for failure to provide complete answers to interrogatories and completely respond to a demand for production of documents by order . 0000015230 00000 n trailer << /Size 549 /Info 514 0 R /Root 520 0 R /Prev 146835 /ID[] >> startxref 0 %%EOF 520 0 obj << /Type /Catalog /Pages 517 0 R /Metadata 515 0 R /OpenAction [ 522 0 R /XYZ null null null ] /PageMode /UseNone /PageLabels 513 0 R /StructTreeRoot 521 0 R /PieceInfo << /MarkedPDF << /LastModified (D:20020103201212)>> >> /LastModified (D:20020103201212) /MarkInfo << /Marked true /LetterspaceFlags 0 >> >> endobj 521 0 obj << /Type /StructTreeRoot /RoleMap 43 0 R /ClassMap 46 0 R /K 352 0 R /ParentTree 497 0 R /ParentTreeNextKey 14 >> endobj 547 0 obj << /S 335 /L 416 /C 432 /Filter /FlateDecode /Length 548 0 R >> stream 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. Unless otherwise specified, the information called for by these interrogatories is limited in scope to information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in the United States. first. 6. Answers to Uniform Interrogatories by Letter of Demand Interrogatories Definition: Written questions submitted to a party from his or her adversary to ascertain answers that are prepared in writing and signed under oath and that have relevance to the issues in a lawsuit. Citing Lehmann v. Toys 'R' Us, 132 N.J. 587, 611 (1993), the New Jersey District Court held that the Plaintiff may use evidence that other women in the workplace were sexually harassed because the plaintiff's work environment is affected not only by conduct directed at herself but also by the treatment of others. Except as otherwise provided by R. 4:17-1(b), the number of interrogatories or of sets of interrogatories to be served is not limited except as required to protect the party from annoyance, expense, embarrassment, or oppression. Interrogatories may, without leave of court, be served upon the plaintiff or answers demanded pursuant to R. 4:17-1(b) after commencement of the action and served upon or demanded from any other party with or after service of the summons and complaint upon that party. The singular form of a noun or pronoun shall be considered to include within its meaning the plural form of the noun or pronoun, and vice versa; and the past tense shall include the present tense where the clear meaning is not distorted. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. %PDF-1.5 14. endstream endobj startxref I understand that submitting this form does not create an attorney-client relationship. Get help from an experienced discrimination lawyer. Insurance Carrier Contact form (online): this form to designate a contact person must be completed by every insurance carriers and self-insurer authorized to do business in NJ. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 %PDF-1.6 % But you have to make sure the client owns the language. Separately for 1997 and each subsequent year, describe in detail and quantify all fees and other income Dentsply collected from third parties relating to training or educating dealers' personnel', dental laboratories' personnel, and dentists, and to the extent possible, allocate the fees and other income between dealers, dental laboratories, and dentists. Secure .gov websites use HTTPS Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 5. 13. Have ever seen someone running away from their answers to discovery at trial? Why do they do it? : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. hbbd``b` $c`b - V0P2$30RNg 2. On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. As a result, we make a lot of diving impossible catches but miss too many fly balls. Hb```f`` Subscriber Application only (fillable): this form needs to be completed if a law firm, insurance carrier or self-insured is interested in adding an additional subscriber to access COURTS on-line and the firm has already established a Contact Person with the Division. L-3773-15. Employee's Claim Petition(can be used for Amended CP), Employee's Claim Petition Supplemental Page, Application for Review or Modification of Formal Award (can be used for Amended ReOpener), Dependency Claim Petition(can be used for Amended DCP), Dependency Claim Petition To Convert Voluntary Tender to Formal Judgment, Notice of Motion for Temporary and/or Medical Benefits(fillable), Standard petitioner's occupational interrogatory form, Second Injury Fund Verified Petition(fillable), Medical Provider Application for Payment or Reimbursement of Medical Payment, Uninsured Employer's Fund Information Packet, Respondent's Answer to Claim Petition (can be used for Amended Answer), Respondent's Answer to Application for Review & Modification of Formal Award (can be used for Amended Answer), Respondent's Answer to Dependency Claim Petition, Answering Statement for Motion for Medical and/or Temporary Benefits(fillable), Respondent's Answer to Medical Claim Petition, Standard respondent's occupational interrogatory form, Request for Adjournment / Ready Hold - page 1 (fillable). District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. of the California Rules of Court, these interrogatories must not be used until the asking party has CN: 10153. {i;6#0O R(VnxTw&:f0L(Y#c{l'tD C]FqC eZ yvm?6=a/DFdrz3 }*S B4,;B@+D\M.F6``CnFwg8#k7"K3T$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; 6/2014. R. Civ. All questions must be answered unless the court otherwise orders or unless a claim of privilege or protective order is made in accordance with R. 4:17-1(b)(3). 0000006225 00000 n www.fraudstoppers.org/wp-content/uploads/Sample-Interrogatories.pdf, Mozilla/5.0 (iPad; CPU OS 15_5 like Mac OS X) AppleWebKit/605.1.15 (KHTML, like Gecko) GSA/219.0.457350353 Mobile/15E148 Safari/604.1. State your company's annual unit and dollar sales separately for each type or line of prefabricated artificial teeth that your company sold or manufactured for each year during the relevant time period. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! In determining the number of questions, you can ask, subparts are counted separately. Interrogatories (NJ) by Practical Law Litigation Maintained New Jersey Sample interrogatories for counsel to use in cases pending in the New Jersey Superior Court, Law Division, Civil Part or Chancery Division, General Equity Part. CN: 10160. (c) In response to any interrogatory, you are permitted to provide copies of business 19. They are just looking for creative ways to circumvent answering discovery. Write in plain English and keep in mind that these responses can be read to a jury. interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys. New Jersey Divorce - Discovery - Interrogatories State: New Jersey Change state Control #: NJ-021B-D Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide All forms provided by US Legal Forms, the nations leading legal forms publisher. 2. Interrogatories are written sets of questions that both sides of the case can send to one another. 0000038018 00000 n hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 Share sensitive information only on official, secure websites. CN: 10151. Browse Workers Compensation forms and publications below. So asking an interrogatory with several questions does not help keep the number down. %PDF-1.5 % Sample interrogatories for counsel to use in cases pending in the New Jersey Superior Court, Law Division, Civil Part or Chancery Division, General Equity Part. It is trite, but you have to digest each word. x[[o~7+WIA`Ec)4$/]?3CR"%QEcIKsfD6yxnw7|)KOn>$Xsf*Q,-ePY?%7?Ls8ci=`.vJy}B'2El ]X`9O3.QZL}x$c$]QIAK#la7gF`,@RDoWWAuLC'_{qZg.uOV\;NSyd/&ii%x-Y*dH6 .e"U[`lrijlPS(oS.20u,}x7_({po%e5 ;kJ4.r4 cM&^T^g}/2-EC5K4^\x/R!AV%,k|HA cec0&Vx[- }/GW)S!"pD/3_sc7\Z,1rF? Next, the interrogatories will likely ask . An official website of the United States government. R. Civ. Make your practice more effective and efficient with Casetexts legal research suite. Except as otherwise provided by R. 4:17-4(e), if a party who has furnished answers to interrogatories thereafter obtains information that renders such answers incomplete or inaccurate, amended answers shall be served not later than 20 days prior to the end of the discovery period, as fixed by the track assignment or subsequent order. Amendments may be allowed thereafter only if the party seeking to amend certifies therein that the information requiring the amendment was not reasonably available or discoverable by the exercise of due diligence prior to the discovery end date. Rule 4:17-4. Princeton, New Jersey 08542-0627 Tel. "Including" means including, but not limited to. R. Civ. 3.5.2 SP6 (5110) Limitation of Interrogatories. 8')@:K6Z/ Y4=U)a6!)J(Q\Sq2/+'2o T3+JSm$2_N?gg2^PERQ&pdY|CqoWU[]? ryn^'g$~8`I;rgpq|Ze_!vrE The term "document" includes all drafts of a document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. For any paragraph that requests information relating to supplying, manufacturing, distributing, selling, or advertising or promoting products in any country other than the United States, the information called for includes all information in your possession, custody or control maintained in both the United States or in any other country. "Exclusive arrangement with a dealer" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person; or. Identify the person signing and attesting to the truthfulness of these Interrogatories, and, if a different individual, the custodian of any business records relating to the premises. This is a checklist you might want to consider in providing answers to this discovery: There is one more really important thing to keep in mind. They are to be answered by you fully, in writing, on oath, and within 30 days of their receipt, unless by agreement or Court order such time is extended: (a) These Interrogatories are continuing in character, so as to require you to file supplemental answers at . (Caption) 1. Rule 4:17-8. State your company's annual unit and dollar sales, separately for each type or line of prefabricated artificial teeth your company sold or manufactured in any country other than the United States, separately for each such country, and separately for 1985 and each subsequent year. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. b. has the purpose or effect of encouraging any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person. State your full name, home address, business address, and occupation. 0000004058 00000 n . APPELLATE DIVISION. I, I, XXX certify that on this 29th day of the month of October, 2009. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Art of Advocacy: Preparation of the Case 1. The list below contains the sample NJ divorce documents discussed above. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. DOCKET NO. e. in the case of an agreement, its date, the place where it occurred, the identity of all persons who were parties to the agreement, the identity of each person who has knowledge of the agreement and all other persons present when it was made, and the subject matter of the agreement. 0000004028 00000 n This Standard Document has integrated notes with important explanations and drafting tips for the caption, introduction, signature block, definitions, instructions, specific interrogatories, and answering party's form certification. Well-drafted interrogatory answers can put more money in your pocket. Service, Scope of Interrogatories (a) Generally. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 Drafting Interrogatories to Support a Fraud Claim by Practical Law Commercial Litigation Maintained USA (National/Federal) A Practice Note explaining the basic considerations for counsel drafting interrogatories to support a common law fraud claim under state law. Sample Plaintiff's Answers to Defendant's Interrogatories. Get a copy to your clients quickly. If an interrogatory has five related subparts, it will be counted as five interrogatories. 0000003987 00000 n 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Part VII offers additional Model Discovery. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 4 0 obj 8. Please read through these Interrogatories and prepare your responses, this will save you time INTERROGATORIES SAIA MOTOR FREIGHT LINE, LLC Information If you contend that Plaintiff has sued the wrong party or that your name is incorrectly stated in this lawsuit, please explain the basis for your contention and identify the correct legal entity for the correct party in interest to this suit. ) FIRST SET OF INTERROGATORIES _____, ) TO DEFENDANT Defendant. ) 34:15-20, Decision of Dismissal (Second Injury Fund), Order for Total Disability with SS Offset (fillable), Order for Total Disability with SIF(fillable), Addendum to Order for Total Disability(fillable), ELECTRONIC CALENDARS, COURTS ON-LINE AND ELECTRONIC FILING FORMS. 1. 7. 0000048970 00000 n Governor Sheila Oliver, Department of Labor and Workforce Development, Reporting work accidents and occupational exposures, Supplemental benefits for public safety workers, 2023 Schedule of Disabilities (updated 1/27/23), Insurance Carrier/ Self-Insurer Contact Listing (updated 8/22), Public Sector Contact Listing (updated 8/22), Report of Compensation Paid (updated 7/22), A Workers' Guide to Workers' Compensation in New Jersey (updated 6/22), Insurance Carrier Contact form (updated 4/22), Hearing Cycle Calendar (updated 3/28/2022), Quarterly Surcharge Return (updated 2/22). HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo 0000049177 00000 n Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. But you are making a mistake if you do not craft interrogatories that are specific to your case. 2013-04-26T13:58:46-05:00 3 0 obj endobj N.J.R. 0000056111 00000 n I also understand that Miller & Zois works with multiple law firms on these claims and that I may be contacted by an affiliated law firm working with Miller & Zois on these lawsuits. 12. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-016-7534, https://content.next.westlaw.com/practical-law/document/Ib7c96852c00111e8a5b3e3d9e23d7429/Interrogatories-NJ?viewType=FullText&transitionType=Default&contextData=(sc.Default). Bring them in for an appointment to go over the answers. It allows you time to be reasonable and time to file a motion to compel long before the discovery deadline. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. "Dental laboratory" means any person that prepares, constructs, assembles or otherwise fills an order or prescription from a dentist for dentures or any other removable or fixed dental prosthetic device, and includes any group, chain or organization of dental laboratories. Your landlord must respond to these requests under oath; they are then admissible in court if you need them. We like to draft some of the answers for them based on their responses to our questionnaire and other information we have, and the clients fill in the blanks. The term "or" shall mean "and" and vice-versa, as necessary to bring within the scope of the following interrogatories all information or documents that would be excluded absent this definition. These are used in conjunction with requests for admission. State whether you purchased the motor vehicle at issue in this litigation (hereinafter referred to as "your vehicle") new or used, and specify: (a) the make, model, and year of your vehicle; It can be either in the form of a question (usually contention interrogatories), or they can direct the answering party to supply accurate information that is described. (Update: Yep, that is what happened!). $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. 0000000951 00000 n Where knowledge, information, or documents are requested, such request encompasses knowledge, information or documents in your possession, custody or control, or in the possession, custody or control of your staff, agents, employees, representatives and, unless privileged, attorneys, or any other person who has possession, custody or control of your proprietary knowledge, information or documents. Unless otherwise specified, these interrogatories are limited to the time period from January 1, 1995, to and including the date of service of these interrogatories. Resource Family Information Form. "Dentsply" means Dentsply International, Inc., each of its predecessors (including Gendex Corporation), successors, divisions, subsidiaries, and affiliates, located both in the United States and in any other country, each other person directly or indirectly, wholly or in part, owned or controlled by it, and each joint venture to which any of them is a party, and all present and former directors, officers, employees, agents, consultants, or other persons acting for or on behalf of any of them.