sample interrogatories nj

55 0 obj <>stream "Including" means including, but not limited to. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. The party serving the interrogatories shall furnish the answering party with the original thereof. R. Civ. 0000015309 00000 n The interrogatories shall be so arranged that after each separate question shall appear a blank space reasonably calculated to enable the answering party to have the answer typed in. 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. But you are making a mistake if you do not craft interrogatories that are specific to your case. % 3. 0000048970 00000 n 0000049177 00000 n 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. We have spent a lot of time fine-tuning our interrogatory questions over the years. We get so much advice as to what we should do. All amendments to answers to interrogatories shall be binding on the party submitting them. 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). We draft our client's answers to save them the hassle of having to do so and because we want to word the responses in a certain way. 0000037811 00000 n Insurance Carrier Contact form (online): this form to designate a contact person must . Washington, DC 20005 . uuid:984c0652-48fa-4f55-badd-b9b174a742c7 They also object because a particular word is not defined (no matter what the word is, right down to question what the definition of "is" is). So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. Sample Plaintiff's Answers to Defendant's 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 Uniform Interrogatories in New Jersey Rule 4 :17-1(b)(2) Cases > > Read More.. %PDF-1.5 % Because the number of requests is restricted without a court order or an agreement among the parties, interrogatories in a complex case should be carefully drafted to request only information that a lawyer cannot find using other discovery mechanisms. New Jersey Form A Interrogatories Form Rating 4.76 Satisfied (292) Discovery Request Sample Form Popularity Notice To Produce Sample Other Form Names Sample Interrogatories Nj Sample Discovery Request Letter Request For Discovery Template Form A Notice Of Motion Nj Motion To Compel Discovery Nj Sample Can you object to form interrogatories? Interrogatories are written questions answered under oath. State your full name, your present address, and date of birth. So both the client and the lawyer are usually involved in preparing these written responses. Complaint for Divorce (with children) Complaint for Divorce (without children) Certification of Insurance (filed with Complaint and Answer) Confidential Litigant Information Sheet (filed with Complaint and Answer) Answer and Counterclaim. List your occupation or job (full and/or part-time) and employers' name and address during the last five (5) years, starting with your present employer. 19. 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. %PDF-1.5 In most jurisdictions, parties may serve 30 written questions. Identify all agreements or contracts between the plaintiff and defendant The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. "Exclusive arrangement with a dental laboratory or dentist" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dental laboratory or dentist to limit the use of, or refrain from using, the products of any other person; or. 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 . 30 0 obj <> endobj Attorneys hate taking positions before trial. 1. Defense counsel in a case recently refused to answer discovery because the defendant thought three sets of requests for admission and interrogatories were just too much. CN: 10151. Figure out how long you have to respond. We have a number of samples in all different types of tort cases above. 4:46-2(c) > > Read More.. MOVING PAPERS Official websites use .gov Very early on during into the case, our lawyers are sure to prepare our clients for the types of questions they shall face not only in a child custody plenary hearing (i.e., trial), but even before the trial begins. Many use this objection to the simplest of questions. 5. 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. 8. stream The user is on notice that neither the State of NJ site nor its operators review any of the services, information and/or content from anything that may be linked to the State of NJ site for any reason. Just think about what you are trying to prove at trial and explore those issues. INTERROGATORIES TO PLAINTIFF Ans. State your full name, home address, business address, and occupation. "Year" means calendar year or the twelve-month period on which your business records are based; if the latter is used in responding to a interrogatory, specify the twelve month period used. It is trite, but you have to digest each word. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 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). 0 Pursuant to Fed. Interrogatories not stricken must be answered within the unexpired period of the sixty (60) days that remained when the notice of motion was served, or as the court directs. Ask defendants the hard questions and ask them early in the case to pin them down (and to have time to file a motion to compel when they don't give complete answers). A. For any record or document responsive or relating to these interrogatories which is known to have been destroyed or lost, or is otherwise unavailable, identify each such document by author, addressee, date, number of pages, and subject matter; and explain in detail the events leading to the destruction or loss, or the reason for the unavailability of such document. Focusing just on this is better than reading a thousand different articles on developing discovery. P. 26(e), you are under a duty seasonably to amend any answer to these interrogatories for which you learn that the answer is in some material respect incomplete or incorrect and if the additional or corrective information has not otherwise been made known to us during the discovery process or in writing. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. 0000015230 00000 n First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. endobj We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Sample Discovery Requests in Personal Injury Lawsuits. 0000003987 00000 n 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. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . 0000006248 00000 n hbbd``b` $c`b - V0P2$30RNg 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. 22. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 %%EOF 8. 1. Hb```f`` R. Civ. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. 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. 0000040914 00000 n 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. Sample interrogatories to the defendant car owner 1. Number of Copies Served; Form of Interrogatories. and CONSTANCE COLEMAN, Plaintiffs-Appellants, . wrP+:y. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. SUPERIOR COURT OF NEW JERSEY. Rule 4:17-1. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. If you think you need an extension to answer, ask for it early. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. Objections to Interrogatories, Rule 4:17-6. Describe in detail and quantify your company's costs or expenses attributable to each dealer to whom you sell prefabricated artificial teeth, separately for each year, and separately for each such dealer, including but not limited to administrative, transactional or other costs or expenses relating to tooth returns or exchanges, drop-shipments, inventory management (including computer hardware or software provided to dealers by Dentsply), training, sales support, marketing, or advertising. "Dealer" means any person that distributes any dental products of any other person or purchases or acquires any such product for the sole purpose of reselling such products to any other person, such as a dental laboratory, dentist, dental school or government entity. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. 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). Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. CN: 10159. Use the saved form as a template for future Adjournment Requests. 0000001829 00000 n 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. Few plaintiffs' attorneys hold their feet to the fire and make them answer in the face of silly objections. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. The State of NJ site may contain optional links, information, services and/or content from other websites operated by third parties that are provided as a convenience, such as Google Translate. You use sample interrogatories because there are some pieces of information you want in every single case. 4!mU>]3Nn6~p ,5_Rn]`R.nQirvuA+`i&.8ZfS |cg2'~pY>+8u4>)n9wv|aS9)y>P4}/fd`0W2bUOg"~yf;+[?JZjbtt5qr'r4"|D>fYLZCCE+zX9/+3qyq#1$x,8U1UBV(hSwa3>"n.$2=b. 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. These are 16.

Senior Living Apartments Based On Income Houston, Tx, University Of Tennessee Parents Weekend 2021, Articles S