INTERROGATORIES TO PLAINTIFF Ans. 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. > > Read More.. 3643, Mark J. Botti William E. Berlin Michael S. Spector Michael D. Farber Health Care Task Force Antitrust Division Washington, D.C. 20004 U.S. Department of Justice 325 7th Street, N.W., Suite 400 Washington, D.C. 20530 (202) 307-0827, Interrogatory Motions, Memoranda, and Orders, This document is available in two formats: this web page (for browsing content) and. NJ Art of Advocacy - Discovery See Part III: Interrogatories and Requests for Production of Documents. 5. 16. hbbd``b` $c`b - V0P2$30RNg Request for Records Inspection: this form must be completed and signed before the Division can release records. Resource Family Information Form (Word form) CN: 10159. 13. 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. 1. Think about the case individually. Next, the interrogatories will likely ask . 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. 33. State the average cost of production of each type or line of prefabricated artificial teeth that your company sold or manufactured for each year. [Source: NJ Court Rules, Appendix II - Interrogatory Forms, Form A(2), #4.] Princeton, New Jersey 08542-0627 Tel. I understand that submitting this form does not create an attorney-client relationship. The following Interrogatories are served upon you pursuant to Fed. Package contains both the Designation of Contact form and Subscriber application form. Number of Copies Served; Form of Interrogatories. "Shade guide" means any device used to match the color or shade of prefabricated artificial teeth to a patient's natural teeth for the specifications contained in a dentist's prescription for dentures or any other removable or fixed dental prosthetic device. 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. %PDF-1.5 % 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? 5. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. SUPERIOR COURT OF NEW JERSEY. I, I, XXX certify that on this 29th day of the month of October, 2009. APPELLATE DIVISION. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. The party to whom interrogatories are propounded may apply for a protective order in accordance with R. 4:10-3. 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* State: (a) the full name and residence address of each defendant . Identify all agreements or contracts between the plaintiff and defendant first. interrogatories attempts to combine "each predecessor, successor, parent, subsidiary, divisions or affiliate" into the entity listed in the request. P. 33, Plaintiff hereby submits the following Interrogatories to Defendant. See, R. 4:17-1(a). Official websites use .gov 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. They are battle tested and we think they are pretty good. 1. endobj Figure out which questions are objectionable. 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. at fniemann@hnlawfirm.com or call him toll-free at (855) 376-5291. 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). Make sure you are not objecting to form interrogatories approved by the court. Please read through these Interrogatories and prepare your responses, this will save you time In the absence of said certification, the late amendment shall be disregarded by the court and adverse parties. DEJON WELCOME, CIEMON MOUZON. 8. "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. The first part of these interrogatories is directed to certain hospital records. 19. 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. 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 See, R. 4:17-4(a). 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. A. Don't take the insurer's set of written interrogatories lightly. 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. 18. 2. _____ Submitted June 6, 2018 - Decided July 10, 2018 Before Judges Currier and Geiger. "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. : (609) 716-6500 Fax: (609) 799-7000 Thomas E. Starnes, Esq. 2. Interrogatories are a big part of the discovery phase of any personal injury lawsuit, and dog bite claims are no exception. SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. Pursuant to Tennessee Rule of Civil Procedure 26.02(5), if any 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. Another tactic that leads to quality information about defendant's case is using alternative interrogatories. Get a copy to your clients quickly. Civil Action No. Frivolous objections come in many shapes and sizes. 0000004058 00000 n 5d;L* 3*3882P_oQNNAhP71:SdNY()a5 R. Civ. Related Forms and Guidance . 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. Service, Scope of Interrogatories, Rule 4:17-2. 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. Except as otherwise provided by R. 4:17-4(e), if a party who has furnished answers to interrogatories thereafter obtains information that renders such answers incomplete or inaccurate, amended answers shall be served not later than 20 days prior to the end of the discovery period, as fixed by the track assignment or subsequent order. application/pdf 15. Allstate GEICO Subpoena to Produce Documents, Information, or Objections or to Permit Inspection of Premises (AO 88b) Category: Civil. These are used in conjunction with requests for admission. (Update: Yep, that is what happened!). 2009-03-16T23:32:54Z 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. 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. 2. endobj 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 2. Toolkit http://www.activepdf.com $Kw<8uCyjd2 ]dg`w+Vf};|"8UkT3)yn d"W2=B4oUcFW5L1}!Afm$_nhX!QxnS5Q~h+^ua]3:*. 1. They quite literally worked as hard as if not harder than the doctors to save our lives. 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. 0000006979 00000 n 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. 0000048970 00000 n 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. 2. Privilege Log. Answers to Uniform Interrogatories by Letter of Demand The objections are, of course, drafted by the attorney. 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 . In a case deemed complex under rule 3.400 et seq. District of New Jersey Home Forms National Forms Official District Court Forms - Official forms are approved by the Judicial Conference of the United States. CN: 10160. Rule 4:17-4. 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). 0000037811 00000 n 30 0 obj <> endobj I do not think she has ever read Maryland Rule 2-421 or Maryland Rule 2-424. 0000056111 00000 n 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. 22. 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. Governor Sheila Oliver, Department of Labor and Workforce Development, Reporting work accidents and occupational exposures, Supplemental benefits for public safety workers, 2023 Schedule of Disabilities (updated 1/27/23), Insurance Carrier/ Self-Insurer Contact Listing (updated 8/22), Public Sector Contact Listing (updated 8/22), Report of Compensation Paid (updated 7/22), A Workers' Guide to Workers' Compensation in New Jersey (updated 6/22), Insurance Carrier Contact form (updated 4/22), Hearing Cycle Calendar (updated 3/28/2022), Quarterly Surcharge Return (updated 2/22). No matter what the objection, the key is to object quickly and press the defendant with a motion to compel if necessary. 21. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases. As a result, we make a lot of diving impossible catches but miss too many fly balls. Secure .gov websites use HTTPS 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. 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. Bring them in for an appointment to go over the answers. Call us today at (856) 685-7420 to schedule a free consultation. 3. Think about the questions that box in the defendant (in one direction or the other). 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). Case Management Order. 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. REV. 0000015309 00000 n Think about the hard questions that you would like to get answers to read to a jury. "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. 6. Call (804) 251-1620 or (757) 810-5614 today. Fillable PDF "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. I am so grateful that I was lucky to pick Miller & Zois. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N.W., Room 400, Washington, D.C. 20530, within 30 days of service of these Interrogatories. <> (Caption) 1. Share sensitive information only on official, secure websites. On appeal from Superior Court of New Jersey, Law Division, Union County, Docket No. Interrogatory No. Bergen County Law Office. 2. 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 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 "You," "your" or "your company" means Dentsply. New Jersey Divorce - Discovery - Interrogatories State: New Jersey Change state Control #: NJ-021B-D Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide All forms provided by US Legal Forms, the nations leading legal forms publisher. 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 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! Read them. The list below contains the sample NJ divorce documents discussed above. 0000040914 00000 n Use, Filing and Effect of Interrogatories. "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. 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. 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. Pursuant to Fed. CN: 10153. 6. Draft your answers. 0000040696 00000 n All rights reserved. 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. 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. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. The interrogatories may include a request, at the propounder's expense, for a copy of any paper. These are Search for another form here. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 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. "Communication" means any disclosure, transfer, or exchange of information or opinion, however made. stream First, serve an initial set as well as later "clean-up" set so long as the total number of questions does not exceed 30. Just think about what you are trying to prove at trial and explore those issues. 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. Local Forms Local forms are drafted and approved by the Clerk's office for the use in the District of New Jersey. 0000006685 00000 n It is not a pretty sight. 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. <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Pursuant to Fed. uuid:984c0652-48fa-4f55-badd-b9b174a742c7 Hb```f`` In most jurisdictions, parties may serve 30 written questions. %PDF-1.5 Proc. *266 Mr. David A. Rappeport, attorney for plaintiff. 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. The party serving the interrogatories shall furnish the answering party with the original thereof. 0000002626 00000 n hJN)OdJBf1GhE wUV4lr1L},rQv'Kwr`qkwFZR&ci1Q 4:46-2(c) > > Read More.. MOVING PAPERS Second Injury Fund Information Review Sheet(fillable), Judgment / Order Approving Settlement(fillable) (with Case Exhibit Listing), Generic Order (for Miscellaneous Decisions, Motions, etc.) Interrogatories are written sets of questions that both sides of the case can send to one another. Objections made thereafter shall not be entertained by the court. Figure out how long you have to respond. 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. Too many lawyers spend a lot of energy drafting great questions only to fall asleep when the defendant provides inadequate answers. 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. Identify the person or persons who had the overall supervision of the subject premises during the period involved in the present suit. {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$222LU4iY6@U@pTnb!]1?=g4spG0 `>X=bkKw#>LPb"; b. has the purpose or effect of encouraging any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person. Use [ edit] 3. "Exclusive arrangement with a dealer" means any proposed or actual agreement, arrangement, policy, program, practice, term or condition of your company that: a. requires any dealer to limit the scope or intensity of effort, or refrain from service, as a dealer for the products of any other person; or. "Base materials" means acrylic or any similar substance used in connection with prefabricated artificial teeth to make dentures. 14. Pursuant to the Rules of Court for the Chancery Division, Family Part, "Interrogatories as to all issues in all family actions may be served by any party as of course" in accordance with Rule 4:17, which applies to Interrogatories for civil practice in New Jersey Courts. The second part of this motion is directed at certain interrogatories, 11 in number, served by the plaintiff upon the defendants. 2 0 obj Washington, DC 20005 . 0000004028 00000 n x[[o~7+WIA`Ec)4$/]?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? Answer each interrogatory fully. The next three sample sets are sent throughout the course of discovery. "Relevant time period" means the time period stated in paragraph 1 of the Instructions. Ans. B P Z b G H X ` m n u h7 h. 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. We get so much advice as to what we should do. 20. Make your practice more effective and efficient with Casetexts legal research suite. (c) In response to any interrogatory, you are permitted to provide copies of business