sample interrogatories nj

They are just looking for creative ways to circumvent answering discovery. 2013-04-26T13:58:46-05:00 previous. Public Sector Contact Listing: similar to above listing, A Workers' Guide to Workers' Compensation in New Jersey, Guia Interpretativa para el Trabajador A la Ley de Compensacion al Trabajador en Nueva Jersey, Second Injury Fund - A Beneficiary's Guide, Employer Notice of Workers' Compensation Insurance Coverage, Application for Review or Modification of Formal Award, Notice of Motion for Temporary and/or Medical Benefits, Respondent's Answer to Application for Review & Modification of Formal Award, Answering Statement for Motion for Medical and/or Temporary Benefits, Request for Adjournment / Ready Hold - page 1, Second Injury Fund Information Review Sheet, Order Approving Settlement under NJSA 34:15-20, Order for Distribution of Temporary Award, Order for Total Disability with SS Offset, Attorney Calendar E-mail Program application, COURTS on-line Internet Access Application, Insurance Carrier / Self-Insurer Contact Listing, Governor Phil Murphy Lt. Use these sample interrogatories however you like. 0000000951 00000 n 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). 5. But you have to make sure the client owns the language. Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. Princeton, New Jersey 08542-0627 Tel. endobj If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. 30 0 obj <> endobj <> 4. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. 2. 4. State your full name, your present address, and date of birth. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . of the California Rules of Court, these interrogatories must not be used until the asking party has The phrase "describe in detail" as used in these interrogatories includes a request for a complete description and explanation of the facts, circumstances, analysis, opinion and other information relating to (as that phrase is defined below) the subject matter of a specific interrogatory. They are battle tested and we think they are pretty good. We have a number of samples in all different types of tort cases above. 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. Think about the case individually. Many use this objection to the simplest of questions. 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. Pursuant to Tennessee Rule of Civil Procedure 26.05(2) these interrogatories are continuing in nature requiring supplementation with such additional information to which you will have access in the future. 0000038018 00000 n Written Questions ("Written Interrogatories") (The court rule about these is CR 33.) 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). Report of Non-Compliance (online): this form may be used by any individual or organization to report allegations of failure on the part of an employer to maintain workers' compensation insurance coverage or obtaining authorization to self-insure. Case Management Order. 0000006979 00000 n %PDF-1.6 % So both the client and the lawyer are usually involved in preparing these written responses. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. 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 (Word form) CN: 10159. Sample Interrogatories for Breach of ContractPlaintiff to Defendant You can find some examples of interrogatories below: Did the defendant execute a written contract with the plaintiff? Think about the questions that box in the defendant (in one direction or the other). 17. 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. A Workers' Guide to Workers' Compensation in New Jersey (legal size paper), Guia Interpretativa para el Trabajador A la Ley de Compensacion al Trabajador en Nueva Jersey (legal size paper), Uninsured Employers Fund Pamphlet: provides the regulations associated with the Uninsured Employers Fund (legal size paper), Second Injury Fund - A Beneficiary's Guide: provides necessary information to recipients of second injury fund benefits. The contact form sends information by non-encrypted email, which is not secure. The last case I referred to them settled for $1.2 million. "Including" means including, but not limited to. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q All amendments to answers to interrogatories shall be binding on the party submitting them. Comments and Help with example of sample interrogatories divorce CIVIL CONVICTION STATUS The following persons: (1) Have been convicted of any felony and, at the time of making the application, did not have a "strike" pursuant to G.S. 3. The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. 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. 0000006685 00000 n Pursuant to Fed. 0000040914 00000 n 14. 0000002216 00000 n Most states allow 30 days to respond (twenty-five in federal court under Rule 33). Call (804) 251-1620 or (757) 810-5614 today. 0000037811 00000 n 15. 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. Form A (2) - Uniform Interrogatories to be Answered by Plaintiff in Product Liability Cases (Other Than Pharmaceutical and Toxic Tort Cases) Only: Superior Court Form B - Uniform Interrogatories to be Answered by Plaintiff: Property Damage to Motor Vehicle: Superior Court* 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream Well-drafted interrogatory answers can put more money in your pocket. The following Interrogatories are served upon you pursuant to Fed. Don't take the insurer's set of written interrogatories lightly. "You," "your" or "your company" means Dentsply. Attorney Calendar E-mail Program application(fillable): this form initiates the transmission of "Attorney Calendar" scheduling notices via e-mail to designated e-mail address(es). "Agreement" means a contract, arrangement, or understanding, formal or informal, oral or written, between two or more persons. and CONSTANCE COLEMAN, Plaintiffs-Appellants, . 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 used in conjunction with requests for admission. COURTS on-line Internet Access Application(fillable): this application package needs to be completed if a law firm, insurance carrier or self-insured is interested in accessing COURTS on-line, the Division'son-line case management website. 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. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. 55 0 obj <>stream Request for Records Inspection: this form must be completed and signed before the Division can release records. INTERROGATORIES TO PLAINTIFF Ans. Rule 4:17-8. 10. 0000006248 00000 n If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. Washington, DC 20005 . . 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. Unless you go over every answer - and even interrogate them just a little bit - there is a chance you are going to get it wrong. uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. "Identify" or "identity" means to state or a statement of: a. in the case of a person other than a natural person, its name, the address of its principal place of business (including zipcode), its telephone number, and the name of its chief executive officer, as well as, if it has a person other than a natural person that ultimately controls it, that other person's name, the address of that person's principal place of business (including zipcode), that other person's telephone number, and the name of that other person's chief executive officer; b. in the case of a natural person, his or her name, business address and telephone number, employer, and title or position; c. in the case of a communication, its date, type (e.g., telephone conversation or discussion), the place where it occurred, the identity of the person who made the communication, the identity of the person who received the communication, the identity of each other person when it was made, and the subject matter discussed; d. in the case of a document, the title of the document, the author, the title or position of the author, the addressee, each recipient, the type of document, the subject matter, the date of preparation, and its number of pages; and. DEJON WELCOME, CIEMON MOUZON. The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Fortunately, we were sure that the judge that hears the motion to compel has read these rules. Sample Interrogatories in Personal Injury and Malpractice Cases. 4 0 obj 1. (b) It is permissible for interrogatories to include a request for a copy of a document. More sample discovery List of Sample Objections Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. A person who receives interrogatories has 30 days to respond in writing. endobj Browse Workers Compensation forms and publications below. 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. See, R. 4:17-1(a). to schedule a free consultation with our team. These are sample written questions that you might receive in your divorce. Next, the interrogatories will likely ask . wrP+:y. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. 9. Ans. 39 0 obj <>/Filter/FlateDecode/ID[<3DE8017F54D98D5939ED3FFC60811FA0><341CF33D3F5EAB49B7E5710A1889DF18>]/Index[30 26]/Info 29 0 R/Length 62/Prev 47862/Root 31 0 R/Size 56/Type/XRef/W[1 2 1]>>stream The term also includes information stored in, or accessible through, computer or other information retrieval systems (including any computer archives or back-up systems), together with instructions and all other materials necessary to use or interpret such data compilations. DOCKET NO. The party serving the interrogatories shall furnish the answering party with the original thereof. (b) Uniform Interrogatories in Certain Actions. 3. 1. In most jurisdictions, parties may serve 30 written questions. Proc. We get so much advice as to what we should do. N.J.R. 20. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. The best advice for propounding, answering and following up on interrogatory answers is the one thing that few attorneys do: put thought into them as to exactly how you are going to use them at trial. Time to Serve Interrogatories. 2. The list below contains the sample NJ divorce documents discussed above. Written responses from a defendant can help narrow down the issues in a case. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. 3. Secure .gov websites use HTTPS -Read Full Disclaimer. This rule does not direct how the questions are to be asked. B P Z b G H X ` m n u h7 h. Superior Court of New Jersey, Law Division. Limitation of Interrogatories. Share sensitive information only on official, secure websites. 8/22. But please read the interrogatories carefully and make sure they fit your case. first. 2009-03-16T23:32:54Z A. In law, interrogatories (also known as requests for further information) [1] are a formal set of written questions propounded by one litigant and required to be answered by an adversary in order to clarify matters of fact and help to determine in advance what facts will be presented at any trial in the case. 0000048970 00000 n 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. 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. The purpose of providing these to our colleagues is that we should all be trying to spend more time maximizing the value of our cases and less time reinventing the wheel. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. 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. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo 519 0 obj << /Linearized 1 /O 522 /H [ 1427 424 ] /L 157345 /E 66972 /N 14 /T 146846 >> endobj xref 519 30 0000000016 00000 n endstream endobj 71 0 obj <> endobj 3 0 obj <> endobj 1 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 5 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 8 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 11 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 14 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 17 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 20 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 23 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 26 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 29 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 32 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 35 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 38 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 41 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 44 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 47 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 50 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 53 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 56 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 59 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 62 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 65 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 68 0 obj <>/Font<>/ProcSet[/PDF/Text/ImageB]>>/Type/Page>> endobj 264 0 obj <>stream 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. 6. The term includes agreements; contracts; letters; telegrams; inter-office communications; memoranda; reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans; drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs; descriptions; drafts, whether or not they resulted in a final document; minutes of meetings, conferences, and telephone or other conversations or communications; invoices; purchase orders; bills of lading; recordings; published or unpublished speeches or articles; publications; transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial statements; microfilm; microfiche; tape or disc recordings; and computer print-outs. Read them. ) FIRST SET OF INTERROGATORIES _____, ) TO DEFENDANT Defendant. ) 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? In determining the number of questions, you can ask, subparts are counted separately. 16. 0000007135 00000 n Art of Advocacy: Preparation of the Case #+wmoSd&Vx7H3"uk]v0 A"`>MB-u6`[dxd;X!CfD3w\BT!g#WQILYgUXTt!2VpPvYpogZzS1(J |J/-T%w5m 1l05Xgh}nH.t`(e@Q:gL^6pVIE)D- {5hMKdzo`-P2d+!Bc~ RTR+[c(GC7N6;4Vl[ 4:46-2(c) > > Read More.. MOVING PAPERS This form must be signed by both the subscriber and the firms Contact Person prior to submitting. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. "Document" means any written, recorded, or graphic material of any kind, whether prepared by you or by any other person, that is in your possession, custody, or control. If you are the site owner (or you manage this site), please whitelist your IP or if you think this block is an error please open a support ticket and make sure to include the block details (displayed in the box below), so we can assist you in troubleshooting the issue. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. Civil Action No. They quite literally worked as hard as if not harder than the doctors to save our lives. 6. The next three sample sets are sent throughout the course of discovery. Insurance Carrier / Self-Insurer Contact Listing: these individuals can be contacted by judicial staff and attorneys where there has been no appearance or formal response made by the carrier or their counsel on pending Motions for Medical and Temporary Benefits. R. Civ. "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. "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. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. Toolkit http://www.activepdf.com 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. 33. If you are unable to answer an interrogatory fully, submit as much information as is available, explain why your answer is incomplete, and identify or describe all other sources of more complete or accurate information. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. HWYoF35- #mV*%.\J7lKBs Q9uqo1Mj/E!e!(#'4@eq}/mwUq|?T0 INTERROGATORIES RELATING TO JURISDICTIONAL DISCOVERY Pursuant to Rule 33 of the Federal Rules of Civil Procedure, Smithfield Foods, Inc. ("SFD") states its responses and objections to Plaintiff's First Set of Interrogatories Relating to Jurisdictional Discovery ("Interrogatories") as follows: GENERAL OBJECTIONS 1. If you think you need an extension to answer, ask for it early. INTERROGATORIES 1. 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. But you are making a mistake if you do not craft interrogatories that are specific to your case. Answer each interrogatory fully. %%EOF CERTIFICATE OF SERVICE. 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. (Update: Yep, that is what happened!). Get help from an experienced discrimination lawyer. 22. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. 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). 7. "Person" means any natural person, corporation, company, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission, office or other business or legal entity, whether private or governmental. 1: State your full name, current address and any and all other names which you have used or by which you have been known. CN: 10153. Objections to Interrogatories, Rule 4:17-6. 12. Part IV - Rules Governing Civil Practice in the Superior Court, Tax Court and Surrogate's Courts, Rule 4:16 - Use of Depositions; Objections; Effect; Errors and Irregularities, Rule 4:18 - Discovery and Inspection of Documents and Property; Copies of Documents. 8. Separately for 1997 and each subsequent year, describe in detail and quantify each separate cost or expense relating to training or educating dealers' personnel, dental laboratories' personnel, and dentists, and to the extent possible, allocate the costs and expenses between dealers, dental laboratories, and dentists.

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