sample interrogatories nj

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. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. 0000001427 00000 n Don't object just because you don't want to answer the question and try to keep the objection as narrow as possible. Think about the questions that box in the defendant (in one direction or the other). The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. 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. 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). Make your practice more effective and efficient with Casetexts legal research suite. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. 11. 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. The objections are, of course, drafted by the attorney. Attorneys hate taking positions before trial. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Related Forms and Guidance . Decided February 14, 1963. > > Read More.. -Read Full Disclaimer. 2. Write in plain English and keep in mind that these responses can be read to a jury. 0000002401 00000 n "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. 0000048970 00000 n "Relevant time period" means the time period stated in paragraph 1 of the Instructions. All amendments to answers to interrogatories shall be binding on the party submitting them. You use sample interrogatories because there are some pieces of information you want in every single case. 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. 6. {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"; State your full name, home address, business address, and occupation. 14. Use these sample interrogatories however you like. 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. Art of Advocacy: Preparation of the Case INTERROGATORIES TO PLAINTIFF Ans. 2009-03-16T23:32:54Z If you object to any interrogatory, state the reasons for objection and answer to the extent the interrogatory is not objectionable. 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. 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. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. Interrogatories in Nursing Home Negligence Cases. 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 0000015309 00000 n On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. 2013-04-26T13:58:46-05:00 Sample NJ Divorce Documents - armourlawfirm.com <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Frivolous objections come in many shapes and sizes. Interrogatories and demands for production to slip and fall defendant 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. 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. APPELLATE DIVISION. INTERROGATORIES 1. 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. In 1994, Maryland Rule 2-421 was amended to allow a party to serve more than a single set of interrogatories. Then draft your discovery and demand answers that fairly and honestly answer the questions. 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. 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). Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] Another tactic that leads to quality information about defendant's case is using alternative interrogatories. 3. Bergen County Law Office. 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. DEJON WELCOME, CIEMON MOUZON. See, R. 4:17-4(a). 3 0 obj PDF Initial Interrogatories With Proof of Service Propounding Party Proc. Case Management Order. Just think about what you are trying to prove at trial and explore those issues. 8. Adobe Acrobat 8.13 Paper Capture Plug-in 0000056111 00000 n 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. DOCKET NO. But you have to make sure the client owns the language. Written interrogatories are a useful discovery tool for plaintiffs in all types of tort cases. Order to Show Cause and to Appoint a Law Guardian with Care and Supervision. Sample interrogatories to the defendant car owner 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. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. "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. (Update: Yep, that is what happened!). 1. The last case I referred to them settled for $1.2 million. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. Formal discovery is the process of serving interrogatories (written questions), requests for documents, or even conducting depositions (sworn, recorded testimony taken before trial). I understand that submitting this form does not create an attorney-client relationship. So asking an interrogatory with several questions does not help keep the number down. Identify all correspondence between plaintiff and the defendant or its representatives, and attach copies. 30 0 obj <> endobj The first part of these interrogatories is directed to certain hospital records. The case settled and I got a lot more money than I expected. Discovery in Landlord and Tenant Cases | Los Servicios Legales de New $@ (&*,RLo0dNevce1%9%CYD}sTwY,Ps`)2ro O}+%=^g[V9zvhbgq1xpBk +C:@D7D2:L0 'h00X@,ggZ `( 4@xK?Hp4p$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 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. "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. 14-36 (relating to strike). Forms | NJ Courts - New Jersey Superior Court You know you have written a poor answer if a juror rolls their eyes when the question and answer are read in court. REV. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - ESSEX VICINAGE 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. "Including" means including, but not limited to. PDF William L. Warren, Esq. DRINKERBIDDLE REATH LLP 105 College Road East "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. 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. 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. 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. 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. Sample Interrogatories in Personal Injury and Malpractice Cases CN: 10151. DOC Plaintiffs' First Set of Interrogatories to Defendant Make sure you are not objecting to form interrogatories approved by the court. Copyright 1999 2023 GoDaddy Operating Company, LLC. %PDF-1.3 % previous. These are sample written questions that you might receive in your divorce. "Relating to" means containing, constituting, considering, comprising, concerning, discussing, regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing, or referring, alluding, or pertaining to, in whole or in part. 8. I am so grateful that I was lucky to pick Miller & Zois. Number of Copies Served; Form of Interrogatories. So if you can pin down what the arguments will be, you will be in a much better position to structure your case effectively. A nursing home defendant should only be required to answer Form C (personal injury) and Form C (3) (medical malpractice) interrogatories, and a . NEW JERSEY'S CIVIL COURT PROCEDURES UPDATED AS OF JANUARY 2011 NEW JERSEY INSTITUTE OF CONTINUING LEGAL EDUCATION One Constitution Square, New Brunswick, N.J. 08901-1520 (732) 249-5100 The New Jersey Institute for Continuing Legal Education Celebrating over 40 years of service to the bench and bar 22. 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. 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.