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 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. to schedule a free consultation with our team. endobj 0000002626 00000 n Draft your answers. Service, Scope of Interrogatories (a) Generally. For any interrogatory or part of an interrogatory which you refuse to answer under a claim of privilege, submit a sworn or certified statement from your counsel or one of your employees in which you identify the nature of the information withheld; specify the grounds of the claimed privilege and the paragraph of these interrogatories to which the information is responsive; and identify each person to whom the information, or any part thereof, has been disclosed. The most classic objection is that the interrogatory asked is objectionable under Maryland law because it is "vague, burdensome, overly broad, and not reasonably calculated to lead to admissible evidence." 0000002957 00000 n 1. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). 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; (c) In response to any interrogatory, you are permitted to provide copies of business Hb```f`` The next three sample sets are sent throughout the course of discovery. Resource Family Information Form. (We do too.) The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. 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. 0000003987 00000 n So asking an interrogatory with several questions does not help keep the number down. 22. Order to Show Cause and to Appoint a Law Guardian with Care and Supervision. This form must be signed by both the subscriber and the firms Contact Person prior to submitting. 0000056111 00000 n Figure out how long you have to respond. See, R. 4:17-4(a). Don't take the insurer's set of written interrogatories lightly. 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. 16. 6. 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. 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! District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. They quite literally worked as hard as if not harder than the doctors to save our lives. 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. Write in plain English and keep in mind that these responses can be read to a jury. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. 1. 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. I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. Questions About Marriage and Marital History. 21. 12. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. and CONSTANCE COLEMAN, Plaintiffs-Appellants, . 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. wrP+:y. 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. first. "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. Interrogatories are written questions answered under oath. 0000040696 00000 n But if the question is overly broad, vague, privileged, or not relevant, you should object. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. All rights reserved. But the pursuit is worth getting proper and complete answers. Washington, DC 20005 . 3. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. Toolkit http://www.activepdf.com %PDF-1.5 % 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. 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 party serving the interrogatories shall furnish the answering party with the original thereof. 4 0 obj 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. N.J.R. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 8. <> Think about the hard questions that you would like to get answers to read to a jury. Hurley v. The Atlantic City Police 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. 0000006225 00000 n ) FIRST SET OF INTERROGATORIES _____, ) TO DEFENDANT Defendant. ) FOR PLAINTIFF UNITED STATES OF AMERICA: Carl Schnee UNITED STATES ATTORNEY FOR THE DISTRICT OF DELAWARE, By: _________________________________ Judith M. Kinney Assistant United States Attorney U.S. Attorney's Office 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277 Delaware Bar No. 11. Unlike oral testimony at a deposition, written statements are much harder to wiggle out of later so interrogatories can be very effective at locking a defendant into a position on key points. A true copy of the 10-page Request for Interrogatories was served on The New Superior Court of New Jersey, Chancery Division - Essex Vincinage, at 212 Wasington Street, Eighth Floor, Newark, New Jersey. . 99-005 (MMS) PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. (b) Uniform Interrogatories in Certain Actions. I, I, XXX certify that on this 29th day of the month of October, 2009. Written Questions ("Written Interrogatories") (The court rule about these is CR 33.) Call me for a free consultation and help with responding to the requests for information. 0000038018 00000 n On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. "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. L-3773-15. 8. 2013-04-26T13:58:46-05:00 Sample Interrogatories From Defendants Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. The responding party must answer in writing and under oath. These questions are referred to as "Interrogatories". 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. 0000001288 00000 n No agreement, understanding, or stipulation by the Department of Justice or any of its representatives purporting to modify, limit, or otherwise vary these interrogatories shall be valid or binding on the Department of Justice unless confirmed or acknowledged in writing (or made of record in open court) by a duly authorized representative thereof. Except as provided in R. 4:17-1(b)(2), initial interrogatories shall be served by plaintiff as to each defendant within 40 days after service of that defendant's answer and each defendant shall serve initial interrogatories within said 40-day period. 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 . THiLfxS^i >T.^%ll_TuFe5c~~1jEWKRd19JY. 2. 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. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. 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. 3. 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. 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). Below is a sample set of interrogatories and requests for production of documents that an injured party (the "plaintiff") might send to the defendant in a slip and fall injury lawsuit. Use, Filing and Effect of Interrogatories. 1. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. 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? "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. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. 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. Number of Copies Served; Form of Interrogatories. It is not a pretty sight. 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. "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. 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* 0000002401 00000 n Defendants and their attorneys tend to use the same standard form interrogatories in all cases so these interrogatory examples should give you a good idea of what to expect. If you have any questions about New Jersey contract law and contract litigation, then please contact Fredrick P. Niemann, Esq. #+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[ A. 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. > > Read More.. All amendments to answers to interrogatories shall be binding on the party submitting them. Call (804) 251-1620 or (757) 810-5614 today. 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. 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. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] This form can now be e-mailed to the individual district offices. It is trite, but you have to digest each word. 3. 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. 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. IN THE COURT OF COMMON PLEAS EIGHTH JUDICIAL CIRCUIT GREENVILLE COUNTY, SOUTH CAROLINA RICHARD A. GORMAN, Plaintiff, VS. JOHN MONARCH, Defendant. 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 . Next, the interrogatories will likely ask . 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. The list below contains the sample NJ divorce documents discussed above. APPELLATE DIVISION. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo Official websites use .gov Accordingly, we suggest serving more than one set. 7. Request for Records Inspection: this form must be completed and signed before the Division can release records. These are used in conjunction with requests for admission. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . 18. 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. Make your practice more effective and efficient with Casetexts legal research suite. The case settled and I got a lot more money than I expected. 7. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. 3.5.2 SP6 (5110) CN: 10153. 6. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 13. Many use this objection to the simplest of questions. Answer each interrogatory fully. Allstate GEICO If you think you need an extension to answer, ask for it early. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. You must answer each interrogatory separately and fully in writing under oath, unless you believe there is a legal reason not to answer it (if you object to it). 0000003166 00000 n Sample interrogatories to the defendant car owner 1. 0 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. $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. <>>> Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 20. While the Interrogatories you receive may not be exactly like these, they will be substantially similar. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. 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. 0000003390 00000 n 0000006685 00000 n Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. Any party may serve upon any other party written interrogatories relating to any matters which may be inquired into under R. 4:10-2. Most states allow 30 days to respond (twenty-five in federal court under Rule 33). The first questions you'll encounter in interrogatories for a loss of consortium will be similar to the kinds of questions you can expect in any kind of injury case: your full name, address, social security number, and possibly your employment information. Insurance Carrier Contact form (online): this form to designate a contact person must . 2. 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. Rule 4:17-8. 0000048970 00000 n We have reports from judges and defense lawyers of lawyers who have cut and pasted example interrogatory questions from our website in their own discovery without even changing all the names and facts. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. "Denture" means artificial teeth fixed in a base material used to replace some or all of a patient's natural teeth. <> 0000015309 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. 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. R. Civ. Think about the questions that box in the defendant (in one direction or the other). The process adds layers of time, expense and tedious effort because a motion must be drafted and typically the judge will require the lawyers to attend a hearing on the motion. 0000015230 00000 n Have ever seen someone running away from their answers to discovery at trial? Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Make sure you are not objecting to form interrogatories approved by the court. 6. 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. 0000002216 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. Form, Service and Time of Answers, Rule 4:17-5. Interrogatory No. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. Focusing just on this is better than reading a thousand different articles on developing discovery. 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? 8/22. 4:17-5(a). 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. %PDF-1.3 % Ans. %%EOF 0000006979 00000 n 0000049177 00000 n 1. 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. Sample Plaintiff's Answers to Defendant's Interrogatories. Princeton, New Jersey 08542-0627 Tel. The following Interrogatories are served upon you pursuant to Fed. State: (a) the full name and residence address of each defendant . SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. "Prefabricated artificial teeth" or "teeth" means any prefabricated (as opposed to dental laboratory or dentist constructed) product used in a denture or as an implant to replace one or more natural teeth. 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. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. In determining the number of questions, you can ask, subparts are counted separately. *266 Mr. David A. Rappeport, attorney for plaintiff. Fillable PDF endobj This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 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. 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). Another favorite objection is that the plaintiff bears the burden, so no answer is required, an objection that is beyond silly. Pursuant to the Rules of Court for the Chancery Division, Family Part, "Interrogatories as to all issues in all family actions may be served by any party as of course" in accordance with Rule 4:17, which applies to Interrogatories for civil practice in New Jersey Courts.
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sample interrogatories nj