In determining the number of questions, you can ask, subparts are counted separately. They are battle tested and we think they are pretty good. 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. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 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. Pursuant to Fed. 6/2014. Service, Scope of Interrogatories, Rule 4:17-2. Interrogatory No. 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. 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. Bring them in for an appointment to go over the answers. Focusing just on this is better than reading a thousand different articles on developing discovery. Use, Filing and Effect of Interrogatories. 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. 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. (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. hVmO8+t&~wR- ,B3vKSx27GdYJH ) SUPERIOR COURT OF NEW JERSEY. 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. 0000056111 00000 n In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. 3. Sample Interrogatories in Personal Injury and Malpractice Cases. DEJON WELCOME, CIEMON MOUZON. Draft your answers. 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). 5. But you have to make sure the client owns the language. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] DOCKET NO. 2. 1: State your full name, current address and any and all other names which you have used or by which you have been known. 2. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. Follow instructions on the form. Download Sample Answer To Interrogatories New Jersey: FileName Speed Downloads Sample Answer To Interrogatories New Jersey [Most popular] 5288 kb/s 1996 Sample Answer To Interrogatories New Jersey | NEW 4174 kb/s 4237 Sample Answer To Interrogatories New Jersey | checked 3591 kb/s 7820 Sample Answer To Interrogatories New Jersey 5834 kb/s 7593 Think about the questions that box in the defendant (in one direction or the other). The case settled and I got a lot more money than I expected. Accordingly, we suggest serving more than one set. Form C. Uniform Interrogatories to be Answered by Defendant in All Personal Injury Cases: Superior Court. The term "document" includes all drafts of a document and all copies that differ in any respect from the original, including any notation, underlining, marking, or information not on the original. Written Questions ("Written Interrogatories") (The court rule about these is CR 33.) "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. Fortunately, we were sure that the judge that hears the motion to compel has read these rules. This form can now be e-mailed to the individual district offices. "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. 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 We have a number of samples in all different types of tort cases above. <> 5. The first step in drafting interrogatories is to find a sample set of interrogatories in a similar personal injury case. (We do too.) 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. N.J.R. 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. interrogatories, please note: (a) You are required to furnish all information available to you, your agents, employees and attorneys. 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 4 0 obj 22. Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. They quite literally worked as hard as if not harder than the doctors to save our lives. 0000001851 00000 n 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. 5. We serve the following localities: Baltimore; Prince George's County including Bowie, Laurel, Landover, Hyattsville; Anne Arundel County including Glen Burnie; Baltimore County including Cockeysville, Glyndon, Hunt Valley, Jacksonville, Lutherville-Timonium, Owings Mills, Parkville, Reisterstown, Plaintiff Attorney Legal Information Center, Example Pretrial Documents for Plaintiff's Lawyers, Sample Discovery Requests in Personal Injury Lawsuits. 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. 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. HWkon-b@@A(GwmQM3g'>/5HddI2/`*KI-?][/ !Yo Bergen County Law Office. Separately for 1990 and each subsequent year through 1996, describe in detail and quantify each separate cost or expense, and all fees and other income Dentsply collected from third parties, relating to training or educating dentists. Insurance Carrier Contact form (online): this form to designate a contact person must be completed by every insurance carriers and self-insurer authorized to do business in NJ. 18. B P Z b G H X ` m n u h7 h. 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. 55 0 obj <>stream This form must be signed by both the subscriber and the firms Contact Person prior to submitting. 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. Don't take the insurer's set of written interrogatories lightly. Browse Workers Compensation forms and publications below. 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." State: (a) the full name and residence address of each defendant . 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. 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. CN: 10160. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. (Update: Yep, that is what happened!). %PDF-1.5 % 0000007135 00000 n L-3773-15. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. Sample Interrogatories From Defendants Below are samples of interrogatories we have received from common defendants in tort cases, such as insurance carriers. 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. REV. These questions are referred to as "Interrogatories". DRINKERBIDDLE & REATH LLP 1500 K Street, N.W. 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. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Insurance Carrier Contact form (online): this form to designate a contact person must . > > Read More.. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) 15. 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. These are used in conjunction with requests for admission. Sample interrogatories to the defendant car owner 1. 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. You use sample interrogatories because there are some pieces of information you want in every single case. 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. (c) In response to any interrogatory, you are permitted to provide copies of business 73 0 obj <> endobj 74 0 obj <> endobj 265 0 obj <>stream _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. I, I, XXX certify that on this 29th day of the month of October, 2009. 7. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. 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? A-4540-16T4 JI SUNG KIM, Plaintiff-Appellant, v. PAUL P. KOBLISKA, Defendant-Respondent. 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; In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. 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. Most states allow 30 days to respond (twenty-five in federal court under Rule 33). 0000004058 00000 n Toolkit http://www.activepdf.com 0000004028 00000 n State the marginal cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. 30 0 obj <> endobj Interrogatories-Limited Civil Cases (Economic Litigation) (form DISC-004)) in the same action. A .gov website belongs to an official government organization in the United States. 0000002957 00000 n 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 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. Sample interrogatories from State Farm in one of Tien Law Firm's personal injury litigation cases, which resulted in a settlement offer from State Farm for our client on the eve of trial. Get help from an experienced discrimination lawyer. 0000002626 00000 n 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. Insurance defense counsel often refuses to answer discovery. Objections to Interrogatories, Rule 4:17-6. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Well-drafted interrogatory answers can put more money in your pocket. 2013-04-26T13:58:46-05:00 But please read the interrogatories carefully and make sure they fit your case. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. P. 26(e), you are under a duty seasonably to amend any answer to these interrogatories for which you learn that the answer is in some material respect incomplete or incorrect and if the additional or corrective information has not otherwise been made known to us during the discovery process or in writing. Few plaintiffs' attorneys hold their feet to the fire and make them answer in the face of silly objections. 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. 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). 1. Request for Adjournment / Ready Hold - additional page** Open form and enter in your firm name and contact info. Think about the hard questions that you would like to get answers to read to a jury. endstream endobj startxref 3. 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. "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. 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? Proc. 6. 0 %PDF-1.6 % Serve a copy of the response to each party in the litigation. 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. Write in plain English and keep in mind that these responses can be read to a jury. "Including" means including, but not limited to. 8/22. Most lawyers work with their clients to get interrogatory answers and then they draft the answers for their client to sign. 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. Copyright 1999 2023 GoDaddy Operating Company, LLC. 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. The next three sample sets are sent throughout the course of discovery. Request for Records Inspection: this form must be completed and signed before the Division can release records. INTERROGATORIES TO PLAINTIFF Ans. The objections are, of course, drafted by the attorney. Then draft your discovery and demand answers that fairly and honestly answer the questions. "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. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT. The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. Many use this objection to the simplest of questions. An official website of the United States government. 1. "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. 2. As a result, we make a lot of diving impossible catches but miss too many fly balls. 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.