sample interrogatories nj sample interrogatories nj

{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"; P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. 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. They are just looking for creative ways to circumvent answering discovery. Official websites use .gov 0000007135 00000 n %PDF-1.6 % 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. 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. Civil Action No. 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. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 14-36 (relating to strike). 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. hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q 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. 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. 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. An official website of the United States government. 697 Valley Street, Suite 2d, Maplewood, NJ 07040 [created January 20, 2011] Page 3 of 6 6. 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. The biggest mistake plaintiffs' personal injury lawyers make after serving interrogatories is not demanding complete answers. 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. Any challenge to the certification of due diligence will be deemed waived unless brought by way of motion on notice filed and served within 20 days after service of the amendment. Most states allow 30 days to respond (twenty-five in federal court under Rule 33). Pursuant to Fed. 4 0 obj 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. Bring them in for an appointment to go over the answers. hbbd``b` $c`b - V0P2$30RNg (Update: Yep, that is what happened!). Objections made thereafter shall not be entertained by the court. New Jersey Interrogatories - Fill Online, Printable, Fillable, Blank 5. stream Fillable PDF But the pursuit is worth getting proper and complete answers. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. "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. PDF First Request for Production of Documents and First Set of Interrogatories Draft your answers. Just think about what you are trying to prove at trial and explore those issues. Litigation Discovery: Interrogatories for an Injury Case Related Forms and Guidance . We get so much advice as to what we should do. 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. Write in plain English and keep in mind that these responses can be read to a jury. 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 (c) In response to any interrogatory, you are permitted to provide copies of business The case settled and I got a lot more money than I expected. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. 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. 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. 12. Interrogatories (NJ) | Practical Law - Westlaw 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). 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. 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. Interrogatories to the defendant car owner - New Jersey Personal Injury (fillable), Order Approving Settlement under NJSA 34:15-20:(fillable) (page 1 and 2), Order for Distribution (for child support), Order for Distribution of Temporary Award (for child support), Affidavit of Dependent in Support of Settlement Under N.J.S.A. 1. You need to mold them to the facts. Get a copy to your clients quickly. Sample Interrogatories | Livinglies's Weblog 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. Insurance defense counsel often refuses to answer discovery. 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. This form can now be e-mailed to the individual district offices. Secure .gov websites use HTTPS 3. 6. These are used in conjunction with requests for admission. A. 7. As a result, we make a lot of diving impossible catches but miss too many fly balls. 1. 0000037811 00000 n 2. 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. 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. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. 0000004028 00000 n "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. Without limitation on the term "control" as used in the preceding paragraph, a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person. Attorneys hate taking positions before trial. 6/2014. PDF William L. Warren, Esq. DRINKERBIDDLE REATH LLP 105 College Road East 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. 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 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. These are 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. 7. Williams v. Marziano :: 1963 :: New Jersey Superior Court, Appellate Make sure you are not objecting to form interrogatories approved by the court. 0000006248 00000 n Few plaintiffs' attorneys hold their feet to the fire and make them answer in the face of silly objections. 0000001829 00000 n We have spent a lot of time fine-tuning our interrogatory questions over the years. Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. Think about the case individually. "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. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. In a case deemed complex under rule 3.400 et seq. #+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[ <>>> 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. 5. Well-drafted interrogatory answers can put more money in your pocket. 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. 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. Objections to Interrogatories, Rule 4:17-6. endobj Plaintiff's First Set Of Interrogatories To Defendant A certification of the amendments shall be furnished promptly to any other party so requesting. 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? The party serving the interrogatories shall furnish the answering party with the original thereof. You use sample interrogatories because there are some pieces of information you want in every single case. PDF SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-4540-16T4 v. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. 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. endobj _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. "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. Allstate GEICO In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 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. The list below contains the sample NJ divorce documents discussed above. State: (a) the full name and residence address of each defendant . 2. 3 0 obj Part VII offers additional Model Discovery. 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. Sample Interrogatories for Assault and Battery to Defendant You are here: Plaintiff's Interrogatories - Assault and Battery by a Third Party How to Discover Information to Get Tort Damages from the Person Who Assaulted and Battered You Assault and battery are not only crimes but also intentional torts under civil law. 0000002216 00000 n 0000006438 00000 n 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. In a New Jersey Child Custody Case, What Kind Of Questions Will I Be Asked? PDF Interrog-P - Judiciary I understand that submitting this form does not create an attorney-client relationship. "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. 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 . The attorneys at Hanlon Niemann have decades of complex trial experience ready to work for you. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Answers to Uniform Interrogatories by Letter of Demand 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. When practicing family law here in New Jersey, one of the most fact sensitive areas for an attorney to handle is a child custody case. %PDF-1.5 3. DEJON WELCOME v. CABLEVISION :: 2009 :: New Jersey - Justia Law 4. 2. APPELLATE DIVISION. But please read the interrogatories carefully and make sure they fit your case. 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. 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream 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). If an interrogatory has five related subparts, it will be counted as five interrogatories. 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. "You," "your" or "your company" means Dentsply. 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. If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. uuid:c389e0db-e0fb-49a3-99ce-ba737d89aee6 <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 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). Ayuda Legal Washington | Elija uno de los temas de abajo para encontrar 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. PDF Husband/Wife'S First Set of Interrogatories Propounded to Wife to The objections are, of course, drafted by the attorney. (legal size paper), Fondo De Segunda Incapacidad - Guia del Beneficiario, WC Research Manual - link to the instructions page, Report of Non-Compliance (online): submit this form to report an uninsured employer, NJ Benefit Letter - Medical Only:document maintained at the Compensation Rating and Bureau (NJCRIB) website, NJ Benefit Letter - Indemnity:document maintained at the Compensation Rating and Bureau (NJCRIB) website, NJ Benefit Letter Usage Directions:document maintained at the Compensation Rating and Bureau (NJCRIB) website. 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. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. "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. Visit our law office in Bergen County or give us a call at (201) 487-1199 to schedule an appointment. 9. R. Civ. Contact the experienced family attorneys at Arons & Solomon Divorce Lawyers today for legal assistance. Exhibit C Defendant Monarch's responses to first set of interrogatories 2. 16. 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. 0000015230 00000 n to schedule a free consultation with our team. Limitation of Interrogatories. The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. hb```f``Rcf`ah``MA;BEam+-= U"v(f`'LAsHPQH3q30 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. 0000002626 00000 n 7. "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. If you believe your employer decided against promoting you because of a discriminatory reason, you should talk to the attorneys at Swartz Swidler. 22. b. has the purpose or effect of encouraging any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person. 0000001851 00000 n This form must be signed by both the subscriber and the firms Contact Person prior to submitting. Service, Scope of Interrogatories, Rule 4:17-2. 4. But you are making a mistake if you do not craft interrogatories that are specific to your case. INTERROGATORIES 1. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). Case Management Order. 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; Why do they do it? 3.5.2 SP6 (5110) Interrogatories are written sets of questions that both sides of the case can send to one another. (Caption) 1. Below are example interrogatories in many different types of personal injury cases for you to use to help you prepare interrogatories in your case. Adobe Acrobat 8.13 Paper Capture Plug-in Interrogatories - Wikipedia A-5298-07T25298-07T2. 0000056111 00000 n It is trite, but you have to digest each word. 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. Rule 4:17-4. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$T`bm20)0 \ endstream endobj 548 0 obj 301 endobj 522 0 obj << /Type /Page /Parent 516 0 R /Resources << /ColorSpace << /CS2 529 0 R /CS3 530 0 R >> /ExtGState << /GS2 538 0 R /GS3 540 0 R >> /Font << /TT4 528 0 R /TT5 523 0 R /TT6 525 0 R /TT7 533 0 R /C2_1 536 0 R >> /ProcSet [ /PDF /Text ] >> /Contents 531 0 R /MediaBox [ 0 0 612 792 ] /CropBox [ 0 0 612 792 ] /Rotate 0 /StructParents 0 >> endobj 523 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 32 /Widths [ 250 ] /Encoding /WinAnsiEncoding /BaseFont /JOMFEK+Garamond /FontDescriptor 526 0 R >> endobj 524 0 obj << /Type /FontDescriptor /Ascent 1005 /CapHeight 718 /Descent -220 /Flags 32 /FontBBox [ -115 -307 1260 1122 ] /FontName /JOMFLP+CenturyGothic-Bold /ItalicAngle 0 /StemV 136 /FontFile2 546 0 R >> endobj 525 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 85 /Widths [ 280 0 0 0 0 0 0 0 0 0 0 0 0 0 280 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 740 0 780 700 520 480 840 0 280 0 0 0 0 740 840 0 0 580 520 420 640 ] /Encoding /WinAnsiEncoding /BaseFont /JOMFLP+CenturyGothic-Bold /FontDescriptor 524 0 R >> endobj 526 0 obj << /Type /FontDescriptor /Ascent 861 /CapHeight 0 /Descent -263 /Flags 34 /FontBBox [ -139 -307 1063 986 ] /FontName /JOMFEK+Garamond /ItalicAngle 0 /StemV 0 /FontFile2 537 0 R >> endobj 527 0 obj << /Type /FontDescriptor /Ascent 905 /CapHeight 718 /Descent -211 /Flags 32 /FontBBox [ -665 -325 2028 1037 ] /FontName /JOMEEJ+Arial /ItalicAngle 0 /StemV 94 /XHeight 515 /FontFile2 539 0 R >> endobj 528 0 obj << /Type /Font /Subtype /TrueType /FirstChar 32 /LastChar 167 /Widths [ 278 0 355 0 556 0 0 0 333 333 0 0 278 333 278 278 556 556 556 556 556 556 556 556 556 556 278 278 0 0 0 556 0 667 667 722 722 667 611 778 722 278 500 0 556 0 722 778 667 0 0 667 611 0 0 944 0 667 0 0 0 0 0 0 0 556 556 500 556 556 278 556 556 222 222 500 222 833 556 556 556 556 333 500 278 556 500 722 500 500 500 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 222 333 333 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 556 ] /Encoding /WinAnsiEncoding /BaseFont /JOMEEJ+Arial /FontDescriptor 527 0 R >> endobj 529 0 obj [ /ICCBased 541 0 R ] endobj 530 0 obj /DeviceGray endobj 531 0 obj << /Filter /FlateDecode /Length 532 0 R >> stream